Interpretation ID: nht95-3.47

TYPE: INTERPRETATION-NHTSA

DATE: July 18, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

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

TITLE: NONE

ATTACHMT: ATTACHED TO 06/23/95 LETTER FROM YOSHIAKI MATSUI TO CHIEF COUNSEL (OCC 11017)

TEXT: Dear Mr. Matsui:

This responds to your letter of June 23, 1995, asking questions about neon high mounted stop lamps.

The National Highway Traffic Safety Administration answered these questions in the preamble to a notice of proposed rulemaking that was published on June 19, 1995. We assume that you had not received it by the 23rd, and enclose a copy for your informati on.

You will see (center column, page 31940) that Federal Motor Vehicle Safety Standard (FMVSS) No. 108 allows neon tubes as light sources for the center highmounted lamp. Under our interpretation of paragraph S5.1.1.16, FMVSS No. 108 also allows testing of a neon lamp with or without its ballast, in accordance with the directions of that paragraph.

If you have any questions, you may refer them to Taylor Vinson of this Office.