Interpretation ID: aiam3401
P.O. Box 581
Bronxville
NY 10708;
Dear Mr. Frail: This is in reply to your letter of April 9, 1981, to this agenc asking, with respect to Motor Vehicle Safety Standard No. 108, 'whether the minimum edge to edge separation distance between lamp and tail or stop lamp of 4 inches is measured *outside* of the lamp or *inside of the lamp*.' You have asked this question in behalf of an 'OEM supplier' in Germany.; The requirement in Table IV of Standard No. 108 is that the minimu edge to edge separation distance between a turn signal lamp and a tail or stop lamp be 4 inches while the turn signal lamps themselves must have a minimum separation distance of 9 inches between their centerlines. (Your design is somewhat confusing as it depicts centerlines of stop lamps and turn signal lamps at 9 inches.) We interpret this as meaning the minimum separation distance between the edge of lighted area to be 4 inches, as depicted in 'B' in your design. Of course, final responsibility for compliance with this requirement rests on the vehicle manufacturer rather than the equipment manufacturer.; Sincerely, Frank Berndt, Chief Counsel