Interpretation ID: 2954o
Technical Administrative Department
Koito Mfg. Co., Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-shi, Shizuoka-Ken
Japan
Dear Mr. Iwase:
This is in reply to your letter of February 22, 1988, asking whether location of a stop and taillamp on a deck lid would comply with Federal Motor Vehicle Safety Standard No. l08. In your opinion this is acceptable because the vehicle complies with the trunk lid closed. You have also asked, alternatively, whether the deck lid is an acceptable location for turn signal lamps.
Section S4.3.1 of Standard No. 108 requires lighting devices to be mounted on "a rigid part of the vehicle...that is not designed to be removed except for repair". In past interpretations the agency has stated that a deck lid is "a rigid part of the vehicle", and that compliance with the standard will be determined with the deck lid closed. Thus, it may be used for mounting lamps and reflectors required by Standard No. 108. However, Table IV specifies the location for rear lamps. Stoplamps, taillamps, rear turn signal lamps, and rear reflex reflectors must be mounted "as far apart as practicable". Although the determination of practicability is initially made by the vehicle manufacturer, the agency in its enforcement efforts would consider whether lighting equipment mounted on the deck lid meets the requirements of Table IV. On the other hand, the separation requirement is not specified for backup lamps and license plate lamps.
I have enclosed for your information a copy of a l980 interpretation that addressed a similar question. As you will note, the agency raised some safety concerns in that letter which could also pertain to your design.
Operation of a motor vehicle in the United States is subject to the laws of the individual States, some of which may prohibit operation of a vehicle when its turn signals and stop lamps are not visible. In summary, we urge you to consider the issues described above, including those raised in the l980 letter, in deciding whether to proceed with this design.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
ref: 108 d:9/l5/88