Interpretation ID: nht95-3.25

TYPE: INTERPRETATION-NHTSA

DATE: June 23, 1995

FROM: Yoshiaki Matsui -- Manager, Automotive Equipment, Legal & Homologation Section, Stanley Electric Co. Ltd.

TO: Chief Counsel, NHTSA

TITLE: Re.: Neon High Mounted Stop Lamps

ATTACHMT: ATTACHED TO 7/18/95 LETTER FROM JOHN WOMACK TO YOSHIAKI MATSUI. (REDBOOK 2; STD. 108)

TEXT: Dear Sir,

We are planning to develop high mounted stop lamps with neon tubes as their light sources.

During the last SAE meeting in Scottsdale, we heard Mr. van Iderstine mentioned that some new regulatory requirements should be provided for neon as light sources. However, we believe it is possible, even at this time, to conduct tests to such stop lamp s in accordance with FMVSS No. 108 and to determine the compliance of the tested high mounted stop lamps to FMVSS No. 108.

Therefore, we would like to ask you to give us your advice to the following questions concerning the acceptability of neon tubes as light sources.

Q1) Are neon tubes accepted as light sources by the current FMVSS No. 108?

Q2) If the answer to the above Q1) is NO, what kind of requirements should be provided to accept the neon?

Q3) If the ballast is integral and indivisible part of a neon high mounted stop lamp, like integral beam headlamps with HID, should such stop lamps be accepted under the current FMVSS No. 108 with no reservation provided the lamp is complied to all requi rements specified in the FMVSS No. 108?

Q4) If the ballast is separable from lamp assembly, should such high mounted stop lamps with neon tube be accepted under the current FMVSS No. 108 or under the amended FMVSS No. 108 allowing such stop lamps in near future?

Your answers will be highly appreciated.