Interpretation ID: aiam4210
Manager
Corporate Technical Affairs
Lucas Industries
Inc.
P.O. Box 7002
Troy
MI 48007-7002;
Dear Mr. Gough: This is in reply to your letter of August 19, 1986, to this Office asking for confirmation of your understanding 'that other light sources can be added to a replaceable bulb headlamp, such as a parking lamp or signal lamp function, as long as the lamps operate independently of each other and are in full compliance with FMVSS 108.'; Your interpretation is essentially correct, and I am enclosing a cop of a recent letter that we sent to Ichikoh Industries on the same subject. In order to be in full compliance with Standard No. 108, if a replaceable bulb headlamp also incorporates a turn signal lamp, the requisite separation distance or candela ratio specified by the standard must be met.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel