Interpretation ID: 86-3.29

TYPE: INTERPRETATION-NHTSA

DATE: 05/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

March 24, 1986 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 January 9, 1986, telling of your development of a center high-mounted stop lamp which would utilize light-emitting diodes (LEDs) as a light source, rather than a light source incorporating a tungsten filament. You have asked whether such a device would be permissible under Standard No. 108. In support of your argument that such a light-producing device would be acceptable, you have brought to our attention paragraph S4.1.1.19 which allows a lamp manufacturer to use "bulbs" that are not listed in SAE Information Report J387 Jul83 is appropriate. The SAE defines a "bulb" as "an indivisible assembly which contains a source of light and which is normally used in a lamp." In further support of your position, you have submitted a summary of test results indication that your LED stop lamp meets all applicable requirements of Standard No. 108, except for S4.1.1.41(e). That subparagraph requires the lamp to "provide access for convenient replacement of the bulb without the use of special tools." We have reviewed your request, and have the following comments. As you have pointed out, Standard No. 108 does not define a "bulb," but we interpret that word in a manner similar to the SAE, that it refers to a photometric performance requirements of Standard No. 108, and you have indicated that your LD4ED lamp complies with these requirements. However, your LED lamp must also meet the requirements of S4.1.1.41(e). Access must be provided for convenient replacement, without use of special tools, of either the individual clusters of LEDs which burn out or the entire lamp. If your lamp is designed so that it meets S4.1.1.41(e) in one of these two ways, then your lamp would appear to be acceptable under Standard No. 108. Sincerely, Original Signed By Erika Z. Jones Chief Counsel