Interpretation ID: nht73-1.35

DATE: 12/19/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Toyo Kogyo U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 6 to Mr. Lewis Owen of this Office concerning the use of a special parking lamp bulb in one of your tail lamp assemblies.

The location of the subject bulb in the lamp assembly, regardless of whether the switch is removed to make it inoperative, is permitted, providing that the other required lamps function as specified in Federal Motor Vehicle Safety Standard No. 108.

Sincerely,

TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

December 6, 1973

Lewis Owen -- National Highway Traffic Safety Administration, U. S. Department of Transportation

Dear Mr. Owen:

This is in confirmation to our discussion on Nov. 27, 1973.

On one of our models, we are now considering to utilize the parts for, between U. S. A. and Japan.

In these rear combination lamps, there are No. 12 lamp, which is called with parking lamp which is different from FMVSS 108. Please find the attached sheet. The parking lamp is required in Japanese regulation, but not required in U. S. A.

We are now thinking it will become irregular if it works. So we want to remove the switch from this lamp and it cannot work. But, for the U. S. A., we want the bulb to remain ( 3.4 W ) and end of coupler and cord.

We must emphasize that there are no influences to another mechanism, ( Stop, tail, & backup lamp ). On the lamp housing, we want to put the caution. This parking lamp is only for Japan namely, "Japan 12 V, 3.4 W". We believe there is no mistake in user.

Warmest regards,

Gorou Utsunomiya -- Branch Manager, Detroit Branch

cc; Dr. Sakashita, Mr. Niguma

Enclosurer