Interpretation ID: nht68-4.17

DATE: 09/17/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr.; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 11, 1968, to Mr. J.E. Leysath of this Bureau, concerning the Chrysler Super Lite which you intend to offer as an optional supplemental light on some of the Chrysler 1969 car lines.

You are correct in your understanding that a supplemental light of this type is not required by Federal Motor Vehicle Safety Standard No. 108. Standard No. 108 does, however, specify, in Paragraph S3.1.2, that no additional lamp, reflective device, or associated equipmont shall be installed if it impairs the effectiveness of the required equipment.

On the basis of our review of your technical literature on the Super Lite and our observation of limited field demonstrations of the light, it does not appear that the Super Lite will impair the effectiveness of the lighting equipment required by Standard No. 108. It should be noted, however, that, while the incorporation of this lamp in your 1969 automobiles would not be precluded by the Federal Standard, the various States may interpose restrictions as to this lamp.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.