Interpretation ID: aiam2998
Manager
U.S. Engineering Office
Alfa Romeo
Inc.
250 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Black: This is in reply to your letter of March 12, 1979, to Mr. Vinson o this office asking for an opinion of whether a red rear fog lamp system would be permissible under Federal Motor Vehicle Safety Standard No. 108 as original equipment. This lamp system would be of the same intensity as the stop lamp system, installed in a separate compartment within the rear lamp assemblies. The system would have a separate switch and be operational only when the headlamp switch is in the 'on' position.; As you have noted, Standard No. 108 does not specify requirements fo either front or rear fog lamps. Lighting equipment supplementary to that required as original equipment may be provided at the manufacturer's option if it does not impair the effectiveness of any equipment installed in accordance with Standard No. 108 (S4.1.3). On the basis of your submission, we are unable to form an opinion whether your system would impair effectiveness with the meaning of S4.1.3. If it is Alfa Romeo's judgment that the red fog lamps will not impair the effectiveness of the taillamps, stop lamps, turn signal lamps or backup lamps, then you may have a reasonable basis upon which to install the fog lamp system and to certify compliance with S4.1.3.; Sincerely, Frank Berndt, Acting Chief Counsel