Interpretation ID: 9948
Triumph Designs Ltd.
Jacknell Road
Dodwells Bridge Industrial Estate
Hinckley, Leics. LE10 3BS
England
Dear Mr. Steffy:
This responds to your FAX of May 5, 1994, to Taylor Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108.
You describe a motorcycle lamp "which comprises a headlight with high and low beams and 2 symmetrically (sic) flanking front auxillary (sic) lamps possessing low beam (sic) that augment the headlight." You ask for our comments.
Paragraph S5.1.3 of Standard No. 108 permits auxiliary lighting equipment provided that it does not impair the effectiveness of the lighting equipment that is required by Standard No. 108. The vehicle manufacturer's certification of compliance with Standard No. 108 includes certification to S5.1.3 and represents its determination that the supplementary equipment does not impair the effectiveness of other lighting equipment. Unless that determination appears clearly erroneous, NHTSA will not question it.
Your letter contains too little information for us to comment further. For example, we do not know whether the candela of the auxiliary lower beam lamps is higher, lower, or the same as the main lower beam of the headlamp. Nor does the letter indicate whether the supplementary lower beam lamps are extinguished when the upper beam is activated.
If you have further questions, we shall be pleased to answer them.
Sincerely,
John Womack Acting Chief Counsel ref:108 d:5/31/94