Interpretation ID: 8049
Hella KG Hueck & Co
Postfach 28 40
4780 Lippstadt
Germany
Dear Herr Schmidt:
This responds to your letter of November 20, 1992, to Richard L. Van Iderstine of this agency asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Please address your future requests for interpretation to the Chief Counsel.
You have asked for confirmation that the requirement that a center highmounted stop lamp "provide access for convenient replacement of the bulb without the use of special tools" does not exclude sealed lamps "where long life light sources like long life bulbs, LED's and neon tubes are provided."
We are pleased to provide the confirmation you request. Although the agency has used the term "the bulb", the term is not meant to exclude more than one bulb, or a light source other than a bulb, for the center lamp. Sealed units (entire lamps) are permissible as long as such a lamp is replaceable without the use of special tools.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:108 d.12/11/92