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Interpretation ID: 86-2.9

TYPE: INTERPRETATION-NHTSA

DATE: 03/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of February 18, 1986, asking whether it is permissible under Federal Motor Vehicle Safety Standard No. 108 to equip a motorcycle with an auxiliary lighting device described in your letter. The device is mounted on an optional trunk and performs the functions of a supplementary taillamp and stop lamp, though its maximum intensities in either mode is less than the minimum required by Standard No. 108 for each such mode.

Under paragraph S4.1.3. a device such as you have described is permissible as original vehicle equipment if it does not impair the effectiveness of the lighting equipment required by Standard No. 108. From your diagram and information, it does not appear that these supplementary taillamp and stop lamp functions will impair the effectiveness of the primary ones, and therefore paragraph S4.1.3 would not prohibit your device.

Sincerely,

Erika Z. Jones Chief Counsel

February 18, 1986

Att.: Ms. Erika Z. Jones Chief Counsel

Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington D.C. 20590 U. S. A.

Re. : Installation of decorative extra lighting device to the vehicle, which is not specified in FMVSS No. 108

Dear Ms. Jones,

We are thinking of producing a decorative extra lighting device which is not specified in FMVSS No. 108.

As shown in the attached sheet, this decorative device will be mounted on the rear face of an optional motorcycle rear trunk. Emitted light color of this extra lighting device is red, and its size is smaller than the tail & stop lamp required in FMVSS No.108. Its function is interlocked with a tail lamp. Its maximum luminous intensity is lower than the minimum photometric requirement of the tail lamp. When the stop lamp is lit, it increases the luminous intensity, but the maximum is lower than the minimum photometric requirement of the stop lamp.

We would like to ask you whether it is permitted to equip a motorcycle with the above mentioned accessory lamp.

We believe that this device have a good effect on the safety by increasing the visibility from upside.

We are looking forward to your advice.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada, Manager, Automotive Lighting