Interpretation ID: aiam1409
Director
Automotive Safety Office
Ford Motor Company
The American Road
Detroit
MI
48121;
Dear Mr. Eckhold: This is in reply to your letter of January 24, 1974, asking for a interpretation as to whether a rear lamp assembly design that Ford demonstrated to NHTSA representatives conforms to the location requirements of Standard No. 108. The assembly consists of three units which, from outboard to inboard, as a rear lighting assembly, comprise the tail lamp/stop lamp, backup lamp, and turn signal lamp.; Standard No. 108 specifies that stop lamps, tail lamps, and turn signa lamps be 'as far apart as practicable.' The standard does not specify a minimum separation distance of lamps, a maximum permissible location inboard, or location of one system relative to another. The determination of practicability in lamp spacing is to be made by the vehicle manufacturer, and the agency has generally afforded manufacturers some latitude in this interpretation.; Therefore, the configuration you have described and demonstrated woul not violate Standard No. 108. It should be noted, however, that it would be in conflict with the requirements for rear turn signals and stop lamps as proposed in Docket 69-19, Notice 3.; Sincerely, James B. Gregory, Administrator