Interpretation ID: nht87-1.5
TYPE: INTERPRETATION-NHTSA
DATE: 01/08/87
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: John B. Walsh -- Corporate Attorney, Manager, Legal Affairs Dept., U.S. Suzuki Motor Corp.
TITLE: FMVSS INTERPRETATION
ATTACHMT: 11/21/84 letter from Frank Berndt to U.S. Suzuki Motor Corp. (Std. 108)
TEXT:
John B. Walsh, Esq. Corporate Attorney Manager, Legal Affairs Dept. U.S. Suzuki Motor Corp. P.O. Box 1100 Brea, CA 92621
This is in reply to your letter of August 15, 1986, to Mr. Vinson of this office, asking for an interpretation of Motor Vehicle Safety Standard No. 108.
You cite Table IV's requirement that the minimum edge to edge distance from a motorcycle's front turn signal to the headlamp be a minimum of inches. Referring to a similar requirement for rear lamp spacing and previous agency interpretations stating that this applies only when there are single rear lamps mounted on the vertical centerline, but not when dual stop and tail lamps are mounted on either side of the centerline, you have asked for an interpretation that an exception from the minimum turn signa l spacing requirement is also permissible when a motorcycle has two headlamps rather than one.
We are unable to provide the requested interpretation because of SAE J588e, September 1970. SAE J588e is incorporated by Standard No. 108 and applies to turn signal lamps in use on passenger cars, motorcycles, and all other motor vehicles. Paragraph 4.2 of SAE J588e establishes the requirement that "the optical axis (filament center) of the front turn signal shall be at least 4 in. from the inside diameter of the retaining ring of the headlamp unit providing the lower beam." This requirement applies reg ardless of the number or location of motor vehicle headlamps. SAE J588e did not prevent the issuance of the earlier interpretations regarding rear lamp spacing since that SAE standard does not establish requirements for minimum separation between turn si gnals and rear lamps.
I hope that this answers your question.
Sincerely, Erika Z. Jones Chief Council
15 August 1986
Mr. Taylor Vinson Room 5219 Office of Chief Counsel. NOA-30 National Highway Traffic Safety Administration 700 Seventh Street. SW Washington, DC 20590
Dear Mr. Vinson:
Subject: Request for Interpretation - FMVSS 108
On November 21, 1984, the Chief Counsel confirmed a 1972 agency interpretation of FMVSS 108, Lamps, Reflective Devices, and Associated Equipment (copy of 1972 interpretation, 1984 request, and your office's 1984 response enclosed). The 1972 interpretatio n was for a motorcycle rear lighting configuration. This letter is to request confirmation that the July 1972 interpretation of FMVSS 108 could apply to a motorcycle front lighting configuration as well as the addressed rear lighting configuration.
Table IV of FMVSS 108 required that motorcycle front turn signals be separated by 16 inches or more (centerline to centerline). and that minimum edge to edge distance from the turn signal to the headlamp be 4 inches or more.
We are exploring the possibility of using a front lighting configuration essentially comparable to current practice in passenger car front lighting configurations. This proposed front lighting configuration would consist of a single lamp unit located nea r the outer edge of each side of the front of the motorcycle. The inboard part of the lamp unit would be the headlamp and the outboard part of the lamp unit would be an amber turn signal lamp. Turn signal lamp separation would be equal to or greater than the 16 inch minimum required (see sketch attached).
We would like you to confirm, as in the 1972 and 1984 interpretations, that the minimum edge to edge separation distance of 4 inches between turn signals and headlamp applies when single headlamps are installed on the vertical centerline, but not when du el headlamps are installed on either side of the centerline.
Thank you for your consideration of this request.
Sincerely,
U.S. SUZUKI MOTOR CORP.
(See 11/21/84 correspondence between Frank Berndt and Suzuki)