ID: nht81-1.38

DATE: 03/13/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Halliburton Services

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Ralph Houser Environmental Engineer Halliburton Services Drawer 1431 Duncan, OK 73536

Dear Mr. Houser:

This is in response to your letter posing a number of questions concerning the application of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) to trucks rebuilt by your company using a variety of new and used components.

Section 571.7(e) of Part 49, CFR, provides that when a new cab is used in the assembly of a truck, the truck will be considered newly manufactured unless the engine, transmissions and drive axle(s) are not new, and at least two of these components were taken from the same vehicle. If the truck is considered newly manufactured, a new vehicle identification number (VIN) must be assigned to the vehicle. In all other circumstances, the vehicle assumes the VIN of the vehicle most significantly represented in the reconstructed vehicle.

Sincerely,

Frank Berndt Chief Counsel

(405) 251-3569 October 29, 1980

Mr. Frederic Schwartz, Chief Council National Highway Traffic Safety Administration Department of Transportation NOA 30 Room 5211 Washington, DC 20590

Dear Sir: RE: 49 CFR Parts 571.7(a), 571.7(e), 571.115

Halliburton Services requests a written interpretation from your office regarding Vehicle Indentification Number (VIN) requirements under the circumstances as described below.

A. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab only. Does this rebuilding operation require the issuance of a new VIN for the truck?

B. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab and a new engine. Does this rebuilding operation require the issuance of a new VIN for the truck?

C. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab, new engine and new transmission. Does this rebuilding operation require the issuance of a new VIN for the truck?

Your assistance in this matter will be greatly appreciated.

Very truly yours,

Ralph Houser Environmental Engineer

RH:jw Certified Mail cc: Nelson Erickson Bill Gilchrist Richard Mize Scott Morris Dale Bragg

ID: nht81-1.39

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 16 1981

NOA-30

Mr. Roy Knoedler Senior Industrial Designer COSCO 2525 State street Columbus, IN 47201

Dear Mr. Knoedler:

This responds to your letter of January 9, 1981, concerning Standard No. 213, Child Restraint Systems. You asked whether a three-point harness system can be used on a rear-facing infant restraint. As explained below, the answer is yes.

Section 5.4.3.3 of the standard sets requirements for the belts or other devices used as an integral part of a child restraint to restrain a child. Section 5.4.3.4 of the standard, referred to in your letter, sets requirements for child restraint systems which consist solely of a harness, such as the Little Rider Child's Safety Harness formerly produced by Rose Manufacturing Co. (The harnesses covered by section S5.4.3.4 of the standard were formerly classified as type III seat belt assemblies and regulated by Standard No. 209, Seat Belt Assemblies.)

Section 5.4.3.3. provides, in part, that its requirements apply to "each child restraint system that is designed for use by a child in a seated position...." In referring to systems that are used by a child "in a seated position", the section is referring to conventional, forward-facing child restraints where the child sits in the restraint in the same manner as he or she would sit in a chair. It does not refer to rear-facing devices for use by infants where the infant is always held in a reclining position.

Because rear-facing restraint systems use the surface behind the child as the primary means of restraining the infants, the belts in such systems are primarily used to control the excursion of the child upon rebound after an impact. Field and laboratory test data available on rear-facing infant restraints indicate that a three point belt system can adequately restraint a child in rebound situations.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Mr. Frank Berndt, Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

January 9, 1981

Dear Mr. Berndt:

Our company would like a written opinion by NHTSA on whether three-point harness systems will be allowed on rear-facing infant car restraints under the specifications outlined in the Standard No. 213-80 "Child Restraint Systems."

There have been rear-facing infant restraints which use three-point harness systems for many years. By a 3-point harness, I mean belts which pass over each shoulder of the child and a crotch strap to which the two shoulder straps attach. This method has been, and still is, being used on rear-facing restraints manufactured or sold by General Motors, Ford, Questor, Century, and Peterson. To my knowledge, there has never been any information gathered to indicate that such harness systems are anything but safe, effective, and convenient methods of restraining rear-facing infants.

It states in the Standard 213 under Section S5.4.3.4. Harnesses "Each child harness shall:

(a) Provide upper torso restraint, including belts passing over each shoulder of the child;

(b) Provide lower torso restraint by means of lap and crotch belt; ..."

Since there is no reference here to whether this applies to rear-facing or forward-facing units, does this mean that a three-point harness would not be allowed on rear-facing infant restraints? Such a requirement would ban from the market many universally recognized safe and effective infant restraints and apparently nothing would be gained in the way of increased safety.

As this may affect our method of manufacture, an early response to this matter will be greatly appreciated.

Sincerely,

Roy Knoedler Senior Industrial Designer

cc: Val Radovich

ID: nht81-1.4

DATE: 01/22/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Davis Trailer Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 7, 1980, letter to Mr. Kratzke of my staff, in which you requested information concerning the legality of using welded mobile home axles and mobile home tires on trailers.

We have no regulations concerning the axles which may be used on trailers. However, the use of mobile home tires on new trailers would violate Federal Motor Vehicle Safety Standard No. 120 (49 CFR @ 571.120). For your information, I have enclosed a copy of this standard. Section S5.1 of the standard requires all new trailers equipped with tires for highway service to use tires that comply with either Standard No. 119, New Pneumatic Tires for Use on Motor Vehicle Other Than Passenger Cars, or Standard No. 109, New Pneumatic Tires -- Passenger Cars. Tires which have the label "For Mobile Home Use Only" have been expressly exempted from the performance requirements of Standard No. 119. Because of the exemption, these tires may only be used on mobile homes. Therefore, the use of these tires on new trailers would render the trailers in violation of Standard No. 120. A manufacturer using these tires on a new trailer would face a fine of up to $ 1,000 for each mobile home tire used, pursuant to the provisions of sections 108 and 109 of the National Traffic and Motor Vehicle Safety Act as amended (15 U.S.C. 1397 and 1398). If you are aware of any such violations, the agency would appreciate any information you could supply.

As I have stated above, we have no regulations specifying performance requirements for the axles on trailers. If you have any further questions or need any further information on this subject, please contact Mr. Kratzke at (202) 426-2992.

Sincerely,

Enclosure

ATTACH.

DAVIS TRAILER MFG CO

NOVEMBER 7, 1980

(Illegible Words)

Dear Sir:

In regards as to our conversation on 11.5.80 I am asking for information on using Mobile Home (Illegible Word) cut into, welded back together an (Illegible Word) to the Public. As you might know on some axles & all mobile home tires are stamped these words. For Mobile Home use only.

If you will mail me some paper work on this matter I will surely appreciate it any information on trailers as to the law of the land. I want to know about it. My competers around me are about to put me out of business using this sort of luck

Hoping to hear from you soon.

Yours truly

Charlton C Davis -- OWNER, Davis Trailer Mfg. Co

ID: nht81-1.40

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; J. Zemaitis; NHTSA

TO: Poly Dyne Engineering

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. Department of Transportation National Highway Traffic Safety Administration

Date: March 16 1981 NO9-00

Subject: Poly Dyne Engineering P.O. Box 3517 Scottsdale, Arizona 85257

From: Motor Vehicle Program Director, Region IX

To: Office of Chief Counsel NOA-30

Enclosed is a letter dated March 6, 1981, and an attached brochure illustrating a reflective device.

We would appreciate your response to the subject.

Joseph Zemaitis

Enclosure

Poly Dyne Engineering Box 3517 Scottsdale, Arizona 85257

March 6, 1981

Joseph F. Zemaitis National Highway Traffic Safety Administration 2 Embarcadero Center, Suite 610 San Francisco, CA 94111 Dear Mr. Zemaitis:

Recently, we have requested copies of regulations pertaining to standards and usage of triangle type flares of warning signals as related to overland trucks. Your office has been helpful in supplying us with copies of current DOT regulations along with procedures to follow for possible amendments.

The purpose of this letter and prior inquiries was to initiate some action that would allow the use of our new patented triangle signal either in addition to or in place of the type that now is carried by truckers to be set on the ground in proper orientation to disabled or parked trucks.

Our product, photos and literature enclosed, has been designed for either rear or side mount on trucks, RVs or any other vehicle and is automatically deployed into its triangular configuration upon withdrawal from the case. Not only is the signal weather tight, but it is permanently mounted on a vehicle and can be rapidly deployed in a matter of seconds or re-encased in the same amount of time. Naturally, the product has been designed to meet DOT specifications for size, reflective surface area, reflectivity and environmental requirements. We have found that a signal of this type mounted a minimum of 3 to 5 feet above the road surface becomes highly visible to approaching traffic from far greater distances than those sitting on the ground. Additionally, they are not subject to the effects of high winds, theft, or the all too common breakage from passing traffic and, by the ease with which they can be deployed, would encourage their use by truckers as well as by RV owners, truck and trailer rental companies, delivery services, etc...We believe that more extensive use of this type of warning device would add significantly to traffic safety.

Needless to say, we are enthused about our new warning signal and have received unusually enthusiastic response from truckers and fleet owners who have seen this device and would like to see it used in place of those now required for road surface display.

We would appreciate your review of the enclosed information as well as your opinion of its benefits and your estimate of the amount of time and effort that may be involved in obtaining DOT approval for its use.

O. Vandewege, Pres. PolyDyne Engineering

OVbb

ID: nht81-1.41

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Columbia Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 16 1981

NOA-30

Mr. David R. Stevens Quality Control Manager Columbia Manufacturing Company Westfield, Massachusetts 01085

Dear Mr. Stevens:

In response to your recent letter, this is to advise you that the 4 mm height requirement for vehicle identification numbers (VIN) does not apply to mopeds (S4.3.1, Federal Motor Vehicle Safety Standard No. 115, 49 CFR 571.115). The letters and number used must be clear, however (S4.3). You should also be aware that if the VIN is to appear on the certification label, it must be at least three thirty-seconds of an inch high (49 CFR 567.4(g)).

Sincerely,

Frank Berndt Chief Counsel

December 29, 1980

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street, S. W. Washington, D. C. 20590

Attn: Mr. Fred Schwartz

Dear Mr. Schwartz:

This is to confirm our phone conversation in that we may use a 3/32 character height for our V.I.N., and that the 4 mm character height doesn't apply to mopeds.

Please find enclosed a sample of cur new V.I.N.

Sincerely,

David R. Stevens Quality Control Manager

DRS/aco

Enc.

ID: nht81-1.42

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: L. O. Willbrand, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Lawrence O. Willbrand, Esq. Suite 873 Paul Brown Bldg. 818 Olive Street St. Louis, MO 63101

RE: Ms. Sharon James

Dear Mr. Willbrand:

This is in reply to your letter of February 19, 1981, with respect to motorcycle tires.

The agency has issued Federal Motor Vehicle Safety Standard No. 119 (49 CFR 571.119), New Pneumatic Tires for Vehicles Other Than Passenger Cars. This standard specifies requirements for new tires designed for highway use on motorcycles, among other vehicle types. I enclose a copy for your information. The agency has issued no standards for off-road vehicle tires such as trail bike tires as our jurisdiction is limited to those items produced for installation on vehicles manufactured primarily for use on the public roads.

If the motorcycle in question was originally sold with trail bike tires installed (i.e., any tire not stamped with a DOT symbol indicating its conformance to Standard No. 119), that sale might be a violation of Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)). But the Act does not prohibit the owner of an on-road motorcycle from putting off-road tires on his bike and using it on the public roads.

If you have any further questions, I would be pleased to answer them.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

February 19, 1981

Federal Motor Vehicle Safety Standards % Department of Transportation Washington, D.C. 20591

RE: Mrs. Sharon James

Dear Sir:

Does your office possess or prepare standards relating to tires on a trail bike or and public road motorcycles.

Specifically I am seeking this material in connection with a tire for said vehicle which propells rocks because the tire was made with "knobs" for trails but was being used on the public roads and had equipment qualifying it to do so.

I would be happy to pay for such materials, references, or citations.

I am most appreciative for any attention you might give this matter.

Very truly yours,

Lawrence C. Willbrand

LCW: mw

ID: nht81-1.43

DATE: 03/16/81

FROM: Frank Berndt -- NHTSA

TO: Burley R. Carpenter

TITLE: FMVSR INTERPRETATION

TEXT:

This is in reply to your letter of February 18, 1981, with reference to your contemplated importation of a BMW passenger car, chassis/serial number 1536114.

Our records confirm your statement that this vehicle was manufactured in the autumn of 1967. Since it was manufactured before January 1, 1968, it may be imported without modifications necessary to meet Federal safety or emission requirements. When your car reaches the port of entry, you will be asked to execute a Declaration Form (HS-7) for safety matters; Box 1 is the appropriate item to check. The car, of course, will have to meet the requirements of the State in which it is to be licensed.

SINCERELY,

FEB. 18, 1981

DIRECTOR OFFICE OF STANDARDS ENFORCEMENT MOTOR VEHICLE PROGRAM U.S. DOT

Dear Sirs,

I am stationed with the US Army in Germany. I own a 1967 BMW, 1600, that I would like to ship back to the U.S. The Chassis/Engine number is 1536114. The local BMW Dealer said that this model was made from 1966 thru 1968. The car was first sold on 20 Nov 1967 this is the only date in the German Tible Book. Can this car be imported into the US without modifications? If not what modifications must be made?

Any information you can give me will be greatly appreciated.

Burley R. Carpenter

ID: nht81-1.44

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nu-Wa Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Neil Ford Plant Engineer Nu-Wa Industries, Inc. P.O. Box 768 Chanute, KS 66720

Dear Mr. Ford

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

December 18, 1980

Administrator, NHTSA

Attn: VIN COORDINATOR

Reference: Vehicle Identification Number

Dear Sir:

Enclosed please find the Vehicle Identification Number (VIN) as established by Nu-Wa Industries, Inc. for Custom Covers and Campers, Inc.

The VIN application for Custom Covers and Campers, Inc. is being submitted by Nu-Wa as an engineering service. Additional computer services and coordination will be required of Nu-Wa as the new VIN system is incorporated by Custom Covers and Campers, Inc.

Custom Covers is a manufacturer or less than 500 units per year.

The target date for affixing the first VIN is January 1, 1981 although the application was not submitted 60 days prior to implementing the system.

Attachment "A" and Attachment "B" are enclosed to illustrate how to decipher the Custom Covers VIN. Attachment "A" describes each character used in the VIN. Attachment "B" indicates a typical Custom Covers VIN and the check digit computation.

The following information determines how to decipher the VIN characters, reference attachment "A" and NHTSA part 571 Federal Motor Vehicle Safety Standards.

1C9 - The first three (3) characters are the World Makers Identification as assigned by the Society of Automotive Engineers, Inc. SAE verification of the assigned number is to be mailed to my attention by January 1, 1981.

3 - The fourth (4th) character indicates the "type"; travel trailer-2, fifth wheel trailer-3, and truck campers-7.

2 - The fifth (5th) character indicates the "number of axles"; one axle-1, two axles-2, three axles-3, and no axles-9.

O - The sixth (6th) character is not used.

L - The seventh (7th) character indicates the units length in feet; 10-12 ft. -D, 12-14 ft. -E, 14-16 ft. -F, 16-18 ft. -G, 18-20 ft. -H, 20-22 ft. -J, 22-24 ft. -K, 24-26 ft. -L, 26-28 ft. -M, 28-30 ft. -N, 30-32 ft. -P, 32 ft. & up -R.

O - The eighth (8th) character is not used.

4 - The ninth (9th) character is the check digit. The check digit is computed as specified per para. 5.2.1 -5.2.4.

A - The tenth (10th) character is the model year as established by table II, paragraph 4.5.3.1.

A - The eleventh (11th) character is the plant location; Custom Covers and Campers, Inc. has only one plant location.

113 - The twelve (12th) thru the fourteenth (14th) characters are the manufacturers world maker identifier as assigned by SAE.

183 - The fifteenth (15th) thru the seventeenth (17th) characters are the sequential numbers as assigned by Custom Covers and Campers, Inc.

Please review the information and advise if any additional information is required or if the Custom Covers and Campers, Inc. VIN is acceptable as submitted.

Thank you for your attention to this matter.

Sincerely,

NU WA INDUSTRIES, INC.

NEIL FORD Plant Engineer

Attachments Omitted.

ID: 86-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Timothy Pawl, P.E. -- President, Pawl Inventioneering Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Timothy Pawl P.E. President Pawl Inventioneering Corporation P.O. Box 5425 West Bloomfield, Michigan 48033

This is in response to your letter of November 29 ,1985, to the former Chief Counsel of this agency Jeffrey R. Miller, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Your letter is vague as to the precise function of your "safety related" lighting device, and whether you wish to offer it as original equipment or equipment intended for installation after the sale of a vehicle to its first purchaser for purposes other than resale. If the latter, then its legality is determinable solely under the laws of each State in which it will be used.

If you intend it as original equipment, on a vehicle at the time of its initial sale, then its legality would be determinable under Standard No. 108. As a general rule, section S4.1.3 prohibits the installation of any device that would impair the effectiveness of lighting equipment required by the standard. You have informed us that your device, which consists of "amber LED's" in the "rear package tray," is inoperative during application of the service brakes; thus, it does not appear that it would impair the effectiveness of the center high-mounted stop lamp.

You have also stated that it is located "in relative proximity" to the center stop lamp but is not combined with it, and you have asked if this meets the intent of S4.4.1 regarding equipment combinations. This section forbids the combination of the center stop lamp with any other lamp or reflective device. Since your device is physically separate from the center lamp, S4.4.1 would not appear to prohibit your device.

You have also stated that when viewed from the rear, "the pattern of illuminated LED's may change, possibly giving the illusion of flashing," and you ask for a definition of "flashing" as described in section S4.6(c). This section has been renumbered S4.5.11, and subsection (c) permits an exception to the general rule that lamps in use must be steady-burning, permitting headlamps and side marker lamps to "flash" for signalling purposes. The definition of flash is that contained in S3, a cycle of activation and deactivation by automatic means, and this definition does not specify frequency or other characteristics. To us, the important question is whether your device complies with section S4.5.11(e) which requires all lamps (other than those specifically excepted) to be steady-burning in use. A lamp that changes patterns may not flash, but it cannot be viewed as steady-burning either.

Finally, you state that "section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps" and ask whether amber or any other color "may be used in proximity" since it is not used in combination. We believe you must be referring to section S4.4.1 which states that "no clearance lamp may be combined optically with any taillamp or identification lamp, and no high-mounted stop lamp shall be combined with any other lamp or reflective device." As we do not know the intended functions of your LED device, I can offer only general comments. Although red is the required color for all rear lighting devices except backup and license plate lamps, amber is permitted as an optional color for rear turn signals: furthermore, amber is generally accepted as indicating the need for caution. Thus, amber is not a lens color whose presence on rear lighting devices would per se impair effectiveness. The use of other colors for lighting devices on the rear of vehicles could lead to confusion, and be viewed as impairing the effectiveness of required lighting equipment.

Sincerely,

Erika Z. Jones

Chief Counsel

November 29, 1985

Jeffrey R. Miller Chief Council U.S. Department of Transportation 400 7th Street S.W. Washington,D.C. 20590

RE: Request for Interpretation of FMVSS 108

Dear Mr. Miller;

We have under development a new device of a safety related nature for automobiles. Before proceeding further on the development, we are hereby requesting an interpretation of Federal Motor Vehicle Safety Standard 108. Our device mounts in the rear package tray area of the automobile. We are therefore concerned about the specific sections pertaining to the operation and restrictions thereof for the Center High Mounted Stoplamp (CHMSL).

As a means of definition of the areas of concern, I will list the specific operating characteristic of our device and then the section from the Standard for which we device an interpretation.

1. Our device has amber colored LED's, during the application of the service brakes, these LED's are disabled ,allowing a vehicle following to observe only the CHMSL. Hence, although in relative proximity (near the target area of the CHMSL) it is not combined with the CHMSL. Does this operation meet the intent of S4.4.1 concerning equipment combinations.

2. When a vehicle containing our device is viewed from the rear by a following vehicle, the pattern of illuminated LED'a may change, possibly giving the illusion or flashing. We therefore need a definition of flashing as described in section S4.6(c), frequency, length of time between periods of "steady-burning" operation, etc.

3. As previously mentioned the device contains amber LED's, section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps.... since it is not used in combination per our question (1) may amber be used in proximity. If not amber, are there any other colors that may be acceptable.

We would appreciate your attention to this matter and await your response. If necessary we may be reached by phone at (313) 682-2007.

Sincerely,

E. Timothy Pawl, P.E. President

ID: 86-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

February 10, 1986 Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan Dear Mr. Chikada: This is in reply to your letter of November 13, 1985, to the former Chief Counsel of this agency, Jeffrey R. Miller, with respect to the ratio of the candlepower between the taillamp, stop lamp, and turn signal lamp (Federal Motor Vehicle Safety Standard No. 108). You have enclosed a hypothetical two-compartment lamp design which could be manufactured in three variations of stop, turn signal, and taillamp combinations (layout 1, layout 2, and layout 3). Standard No. 108 incorporates by reference various SAE standards which prescribe candlepower ratios for multiple compartment lamps (J585e Taillamps; J586c Stop Lamps; J588e Turn Signal Lamps). You ask how you can apply the ratio of the candlepower between the lamps. The requirements to which you refer are contained in Note 4 to Table 1 of each of the referenced SAE standards, which in turn cite paragraph 3.1 of each standard. The first sentence of Note 4 establishes the ratio when one function is combined with another (that is to say, optically combined within a single compartment). The second sentence of Note 4 provides, however, that if a multiple compartment lamp is used and the distance between the optical axis for both functions is within the dimensions specified in paragraph 3.1, the ratio is computed with all the compartments lighted. The third sentence of Note 4 states that if these dimensions are exceeded the ratio is computed for only those compartments where the functions are optically combined. In layout 1 the turn signal lamp is not combined with the tail/stop lamp and you have asked for confirmation that only the ratio between the tail lamp and stop lamp must be considered. That is correct. The dimension specified in paragraph 3.1 of each of the SAE standards is a maximum of 22 inches between filament centers in two-compartment lamps. Your layout 2 combines the tail lamp and turn signal lamp in one compartment, and the tail lamp and stop lamp in the second, whereas in layout 3 the first compartment contains one lamp, the tail lamp, and in the second compartment, the tail lamp, stop lamp, and turn signal lamp are present. You ask for confirmation that only the ratios of the lamps in the individual compartments shall be considered. Your hypothetical lamp design does not depict the distance between filament centers of each function, but if they exceed 22 inches then you are correct with respect to layouts 2 and 3. If the distance is less than 22 inches, then the ratio is computed with both compartments lighted. I hope that this answers your questions.

Sincerely, Original Signed By Erika Z. Jones Chief Counsel