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Interpretation ID: Lewis.2

    Mr. William Heath Lewis
    Automotive Manufacturing Group, Inc.
    d/b/a A.M.G.
    20479 Via Marisa
    Boca Raton, FL 33498


    Dear Mr. Lewis:

    This responds to your July 29, 2004, e-mail to George Feygin in which you ask whether your companys products, truck clearance lamps with "clear application" (presumably emitting a white light), meet the requirements of the regulations of the National Highway Traffic Safety Administration (NHTSA) and how you would go about obtaining DOT approval for those products. Your e-mail attached four photographs of trucks that have a series of lamps on the cab roof, immediately above the windshield. As these depicted vehicles are equipped with both clearance lamps and identification lamps, this letter addresses the requirements for both types of lamps. I am pleased to have the opportunity to explain our regulations and to discuss how they may affect your products.

    By way of background, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment, nor do we issue permits. Instead, it is the responsibility of manufacturers to certify that their products conform to all applicable safety standards before they can be offered for sale (see 49 CFR Part 571). NHTSA enforces compliance with the standards by inspecting and testing vehicles and equipment, and we also investigate possible safety-related defects.

    The requirements for lighting equipment are contained in FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment (see 49 CFR 571.108). The standard sets performance requirements for clearance and identification lamps, including color. Specifically, Table I requires multipurpose passenger vehicles (MPVs), trucks, trailers, and buses that are 80 or more inches in overall width to be equipped with 2 amber clearance lamps and 2 red clearance lamps. Table I also requires those vehicles to be equipped with 3 amber identification lamps and 3 red identification lamps. These lamps must emit amber or red light, respectively.

    Table II of FMVSS No. 108 specifies location requirements for clearance and identification lamps. Specifically, the standard requires two amber clearance lamps on the front and two red clearance lamps on the rear to indicate the overall width of the vehicle. The clearance lamps must be located, one on each side of the vertical centerline, at the same height, and as far apart as practicable.

    Table II also requires covered vehicles to be equipped with identification lamps on the front and rear of the vehicle. The standard requires three amber lamps on the front and three red lamps on the rear of the vehicle. The identification lamps are to be located as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline, and with lamp centers spaced not less than 6 inches or more than 12 inches apart. Alternatively, the front lamps may be located as close as practicable to the top of the cab.

    These requirements related to the color of clearance and identification lamps apply to both original equipment and replacement (aftermarket) lighting equipment. Paragraph S5.8.1 of the standard provides that " each lamp, reflective device, or item of associated equipment manufactured to replace any lamp, reflective device, or item of associated equipment on any vehicle to which this standard applies shall be designed to conform to this standard. "

    In light of the above and based upon the location of the lighting equipment in the photographs accompanying your correspondence, the standard requires your clearance lamps (or identification lamps) to emit amber light. However, we note that manufacturers are not required to use an amber lens to comply with the color requirements for an amber lamp. Rather, they may use any plastic material that complies with the requirements of paragraph S5.1.2, as long as the light emitted from the completed lamp complies with the applicable color requirements.

    For your further information, I am enclosing a fact sheet we prepared titled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment. I hope you find this information useful. If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    Enclosure
    ref:108
    d.9/23/04