Interpretation ID: 86-3.18

TYPE: INTERPRETATION-NHTSA

DATE: 05/08/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Manager, Technical Administration Department Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan

Dear Mr. Iwase:

This is in reply to your letter of March 28, 1986, asking about the permissibility under Motor Vehicle Safety Standard No. 108 of two different designs of supplementary parking lamp systems.

In your first design, the vehicle headlamps on each side are bracketed by two parking lamps, the one closest to the vehicle edge termed "obligatory" and the inner one "supplementary." Both are designed to comply with Standard No. 108. Paragraph S4.1.3 of Standard No. 108 permits the installation of supplementary lighting equipment as long as it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires. From the information you have provided us, it would not appear that the supplementary parking lamps designed to meet Standard No. 108 would impair the effectiveness of the headlamps, turn signal lamps, or "obligatory" parking lamps.

In your second design, the "obligatory" parking lamps remain outboard of the vehicle's headlamps but a single supplementary parking lamp is installed on the centerline of the vehicle. This lamp will also be designed to comply with the parking lamp requirements of Standard No. 108. From your drawing, it appears that this lamp extends from the centerline almost to each headlamp. This supplementary lamp is also subject to the same restrictions of S4.1.3. Although the design is unusual, the low photometric output associated with parking lamps should insure that this lamp does not impair the effectiveness of Standard No. 108's required lighting equipment.

I hope that this answers your questions.

Sincerely, Original Signed By

Erika Z. Jones Chief Counsel

Air-Mail (1/2)

Ms. Erika Z. Jones Date: Mar. 28, 1986 Chief Counsel Ref No.86.03.28.01 National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Supplementary Parking Lamp

Dear Sir:

Many thanks for your kind consideration which you have extended to us.

We would hereby ask for your kind advice to the subject matter.

In S4.1.1 and Attached Table III of FMVSS No. 108, passenger cars of less than 80 inches overall width are required to be equipped with at least one(1) parking lamp on each side of the vertical centerline.

According to this prescription, a supplementary parking lamp is being equipped on passenger cars in addition to an obligatory parking lamp which is specified in the FMVSS No. 108.

We would hereby ask you to provide us with your kind advice as to whether such a supplementary parking lamp as shown in Case-A or Case-B could be accepted or not under the FMVSS No. 108.

"INSERT FORMULA"

Supplementary Parking Lamp Headlamp obligatory Parking Lamp specified in FMVSS No. 108

Note: 1. A supplementary parking lamp will be installed on each side of the vertical centerline and located adjacent and inner to headlamps.

2. This supplementary parking lamp will be designed to comply with the requirements of performance specified in FMVSS No. 108.

Atten.: Ms. Erika Z. Jones Date : Mar. 28, 1986

Case-B:

Supplementary Parking Lamp Headlamp obligatory parking Lamp specified in FMVSS No. 108

Note: 1. A supplementary parking lamp will be installed on the centerline of vehicle.

2. This supplementary parking lamp will be designed to comply with the requirements of performance specified in FMVSS No. 108.

Upon your kind review to this matter, your kind and prompt reply would be greatly appreciated.

Yours very truly,

M. Iwase, Manager Technical Administration Dept. KOITO MANUFACTURING CO., LTD. Shizuoka Works