Interpretation ID: 21899.ztv

Mr. Noburu Fujii
Director, Technical Affairs
Nissan North America, Inc.
Government Affairs Office
196 Van Buren Street, Suite 450
Herndon, VA 20170-5337

Dear Mr. Fujii:

This is in reply to your letter of July 7, 2000, with respect to "whether a sliding door system for use in a passenger motor vehicle meets certain requirements of FMVSS 108." Specifically, you ask "whether the potential obstruction of the rear sidemarker lamp, rear side reflex reflector, and rearward signals/markers when the sliding door is fully opened would violate any provisions of FMVSS 108." You have referred to our letter of April 8, 1998, to Pat Riebalkin, informing him that "compliance is judged with a motor vehicle in its normal operating configuration (e.g., doors and decklid closed.)"

We are pleased to inform you that the Riebalkin interpretation applies to Nissan as well. The lighting equipment in question will not be obstructed when the Nissan vehicle is in its normal on-road operating configuration (e.g., sliding door closed.) There is no need to provide auxiliary lighting equipment under FMVSS 108. However, this interpretation does not apply in Canada. We believe that Canada has a different interpretation, and recommend that Nissan consult Transport Canada for its views.

Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:108
d.1/19/01