Interpretation ID: aiam0230
Esq.
119 West 57th Street
New York
New York 10019;
Dear Mr. Sugarman: In response to your letter of April 16 I enclose copies of Federa Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, 'SAE Technical Reports Referenced in Federal Motor Vehicle Safety Standards'.; The answer to your first question is that Standard No. 108 require passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle 'as far forward as practicable', and one marker and one reflector, red in color, on each side of the vehicle, 'as far to the rear as practicable'. Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverdi displayed at the recent New York show were amber and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standard applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.; In answer to your second question, Table III of Standard No. 10 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.; You have asked in your third question whether headlamps may be place in the grille. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.; Standard No. 107 does not specify a particular color for the horn rin and hub of the steering assembly but it does specify a maximum permissible value for specular glass.; Finally, other than Standard Nos. 205 (Glazing Materials) and 21 (windshield Mounting which all passenger cars must meet, there is no 'specific safety requirement as to the windshield' for convertibles, and there is no 'requirement as to a roll bar'.; Sincerely, Lawrence R. Schneider, Chief, Regulations Division