Interpretation ID: 2860yy
President
Automotive Safety Testing, Inc.
at TRC of Ohio, Bldg. 20
Rd. 152 & SR 33
East Liberty, OH 43319
Dear Mr. Peterson:
This is in reply to your letter of February 7, l99l, to the Office of Chief Counsel asking for a clarification of allowable mounting locations and photometric output requirements for tail/stop lamps on passenger cars.
One of your clients wishes to mount "two-part" stop/tail lamps "so that one lamp is mounted on the fixed quarter panel and a duplicate lamp is mounted on the trunk lid." Each part of the two-part lamp is a combination tail/stop lamp. You have asked whether the minimum photometric requirements must be met by "the lamp mounted to the quarter panel or may the portion mounted on the trunk lid count toward the photometric requirements."
Your "two-part lamp" would be treated as two separate lamps. For purposes of compliance, only one of these two adjacent lamps must be designed to conform to Standard No. l08, and this conformance must be independent of any "contribution" by the adjacent lamp. Although Standard No. l08 permits either the deck or the body mounted lamp to be the complying lamp, it would be our preference that the body mounted lamp be the one that complies, so that the benefit of a conforming stop/tail lamp would be realized during those occasions when the lid may be raised.
Sincerely,
Paul Jackson Rice Chief Counsel
/ref:l08 d:3/8/9l