Interpretation ID: 1984-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 07/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. C. I. Nielsen III Vice President - Marketing Wesbar Corporation Box 577 West Bend, Wisconsin 53095

Dear Mr. Nielsen:

This is in reply to your letter of May 16, 1984, to Mr. Vinson of this office seeking an interpretation of Motor Vehicle Safety Standard No. 108. You wish to know whether the minimum effective projected luminous lens area for stop lamps and turn signal lamps on trailers whose overall width is 80 inches or greater is 8 square inches or 12 square inches. You cite an apparent conflict between paragraph S4.1.1.6 and SAE Standard J586d, and paragraph S4.1.1.7 and SAE Standard J588f. You have asked for an interpretation so that Wesbar may properly design a "combination tail lamp."

First, we will confirm the advice provided by "D.O.T. staff people" that the latest SAE revisions, J586d and J588f, have not been adopted.

You do not state the intended use of your proposed lamp, so we will assume that it will be sold to trailer manufacturers as original equipment, and to the aftermarket as replacement equipment. As original equipment, it must comply with the requirements specified in Table I of Standard No. 108, SAE J586c for stop lamps and SAE J588e for turn signal lamps. Paragraph 3.2 of each standard specifies a minimum effective projected luminous lens area of 8 square inches.

Paragraphs S4.1.1.6 and S4.1.1.7 become relevant, however, if Wesbar intends the lamp as replacement equipment on trailers manufactured before September 1, 1978, and after January 1, 1972 (turn signal lamps) and January 1, 1973 ( stop lamps). Under paragraphs S4.1.1.6 and S4.1.1.7 replacement stop and turn signal lamps for trailers manufactured within the 1972-1978 time frame may meet either J586b or J586c, and either J588d or J588e. We note that neither J586b nor paragraph S4.1.1.6 establish a minimum luminous lens area for stop lamps. However, a manufacturer who chooses to comply with paragraph S4.1.1.7 rather than J588e would have to provide the minimum specified luminous lens area of 12 square inches for turn signal lamps of trailers whose overall width was 80 inches or more, the requirement specified in J588d for Class A turn signal lamps. We view this interpretation as one of historical interest than current relevance.

In summary, if Wesbar designs its lamp to the 8-inch requirement, it would appear to meet specifications for application either as original or replacement equipment.

Sincerely,

Frank Berndt Chief Counsel

May 16, 1984

Department of Transportation 400 - 7th Street SW Washington, D.C. 20590

Attention: Mr. Taylor Vincent, Legal Counsel

Dear Mr. Vincent:

Re: Request for D.O.T. 108 Interpretation

Wesbar is a lamp manufacturer currently designing a new submersible boat trailer lamp, which we would like to introduce this fall at the national trade show. The reason we are writing you at this time is that we find we have a need for a written interpretation clarifying a section of Federal Motor Vehicle Safety Standard No. 108 regarding the lamps used on trailers over 80 inches wide.

The need for the interpretation arrives from several sources, which include the latest SAE Engineering Handbook, several D.O.T. staff, and the marketplace. The area needing clarification is the number of square inches actually needed (of effective projected luminous area) for a STOP LAMP (D.O.T.-108, S4.1.1.6 vs. SAE J586d) and a TURN LAMP (D.O.T.-108, S4.1.1.7 vs SAE J588f). The current SAE Handbook calls out 8 square inches of "effective projected luminous lens" area as the minimum for either a turn or stop lamp used on a trailer 80 inches or more in width. We followed this up by questioning several D.O.T. staff people. They stated the latest SAE standards revisions had not been adopted by D.O.T. and therefore the 12 square inch requirement (of effective projected luminous lens area) must still be met when the light is used on trailers 80 inches or more in width. This was consistent until one staff member learned of Peterson Manufacturing's (Anderson Marine Division) #450 series "8-in-one", which is promoted for use on over 80 inch wide trailers, that has only 8 square inches of lens -- then we were told 8 square inches would be sufficient.

As you are probably well aware, the U.S. marketplace is more price competitive and quality conscious than ever before. Therefore, while we, as a lamp manufacturer, sincerely wish to meet every letter of the law, we also need to be as up-to-date and cost competitive as possible, and this is why we have been directed to you. Is the old standard still current or is a new generation of tail lights, such as Peterson's #450 series submersible tail light, now acceptable to meet the standard?

Thank you in advance for your time and consideration in reviewing this matter. It is important that we receive your written interpretation as soon as possible for it will have great impact on the design and cost of our new proposed combination tail light, as well as keep us "on schedule" for its introduction.

Sincerely,

WESBAR CORPORATION

C. I. Nielsen III Vice President - Marketing

CIN:mk