Interpretation ID: 9181
Manager, LSI Laboratories
Lighting Sciences, Inc.
7830 E. Evans Road
Scottsdale, AZ 85260
Dear Mr. Walker:
We are replying to your letter of October 4, 1993, with respect to the requirements of Federal Motor Vehicle Safety Standard No. 108 for taillamps.
You believe that a discrepancy exists because paragraph S5.1.1 "requires equipment to be designed to Tables I, II [you mean III], and S7, which references SAE J585e for the Tail Lamp," whereas paragraph S5.1.1.11 "requires Table 1 of this specification to be substituted for the values achieved by Figures 1a and 1b, and in addition, to substitute Table 1 of SAE J585e by the values achieved by multiplying the percentages of Figure 1a by Table 1 and 3 of SAE J588 NOV84 Turn Signal Lamps."
You assume that the photometric requirements are those of Figure 1a, 1b, and 1c. Your assumption is correct. However, there is no discrepancy in the standard. The requirements for motor vehicle lighting equipment are set forth in Section S5. Paragraph S5.1.1 requires lighting equipment to comply with the SAE materials contained in the tables, except as may be provided in succeeding paragraphs of Paragraph S5.1.1. Tables I and III incorporate by reference SAE Standard J585e, Tail Lamps, September 1977. However, on March 3, 1993, NHTSA redesignated Paragraph S5.1.1.11 (with its references to Figures 1a and 1b) as S5.1.1.6, and revised it to include, among other things, the reference in paragraph S5.1.1.12 to Figure 1c. The same notice removed paragraph S5.1.1.12 from the standard. New Paragraph S5.1.1.6 states that instead of the photometric values specified in Table 1 of SAE J585e, taillamps shall comply with those of Figures 1a, 1b and 1c.
I enclose a copy of the amendment for your information, and hope that this answers your question.
Sincerely,
John Womack Acting Chief Counsel Enclosure ref:108 d:11/16/93