Interpretation ID: 86-3.13
TYPE: INTERPRETATION-NHTSA
DATE: 05/06/86
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: W.L. Hammer, P.E. -- Equipment Engineer, Wisconsin Electric Power Company
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. W.L. Hammer, P.E. Equipment Engineer Wisconsin Electric Power Company 620 S. 76th Street Milwaukee, WI 53214
This is in reply to your letter of January 29, 1986, asking for an interpretation of the stop lamp and turn signal requirements of Federal Motor Vehicle Safety Standard No. 108.
Your first question is whether paragraphs S4.1.1.6 and S4.1.1.7 apply to vehicles manufactured in 1986. No. They apply to original equipment stop lamps on vehicles manufactured between January 1, 1973 and September 1, 1978 (S4.1.1.6), and to original equipment turn signal lamps on vehicles other than motorcycles manufactured between January 1, 1972, and September 1, 1978 (S4.1.1.7). However, they also apply to stop lamps and turn signal lamps manufactured after September 1, 1978, which are intended as replacement equipment for the original equipment manufactured between the inclusive dates. This is not exactly clear from a reading of the two paragraphs and we are considering a clarifying amendment to the standard. In summary, these paragraphs do not apply to vehicles manufactured in 1986, but they could apply to certain lighting equipment being manufactured today.
You also comment that S4.1.1.6 is silent as to the minimum luminous lens area required for stop lamps on vehicles whose overall width is 80 inches or more, which you recall as once being 12 square inches, and you ask if a final sentence has been omitted pertaining to wide vehicles. There has been no omission: SAE Standard J586b Stop Lamps, June 1966, the standard referenced in S4.1.1.6, never specified a minimum effective projected luminous lens area for wide vehicles. The requirement for wide vehicles today is found in paragraph 3.2 of SAE Standard J586c Stop Lamps, August 1970. This establishes a minimum effective projected luminous lens area of 8 square inches for single compartment lamps. However, paragraph 3.1 allows manufacturers of wide vehicles to mount a maximum of two lamps and/or compartments per side closer together than 22 inches providing that each compartment and/or lamp meets single compartment photometric requirements and has a minimum effective projected luminous lens area of 12 square inches.
I hope that this answers your questions.
Sincerely,
Original Signed By
Erika Z. Jones
Chief Counsel
January 29, 1986 National Highway Traffic Safety Administration 400 Seventh Street SW Washington, D.C. 20590
Gentlemen:
SUBJECT: 49CFR571.108 PARAGRAPH 4.1.1.6 STOPLIGHTS PARAGRAPH 4.1.1.7 TURN SIGNALS
I have been reading 571.108 as published in the 1984 edition of the Code of Federal Regulations. At first glance, Paragraphs 4.1.1.6 and 4.1.1.7 appear to only pertain to certain vehicles manufactured between 1972 and 1978 and not to those made before or after those dates. On a second glance, these paragraphs refer to a design option to meet SAEJ586b or 588d, or to meet SAEJ575d. Do these paragraphs apply to vehicles manufactured in 1986;
Also, in the case of Paragraph 4.1.1.6, a 3.5 square inch rule pertains to vehicles less than 80 inches in width, but there is no comment made for those vehicles over 80 inches in width. (I seem to remember it once was 12 square inches). Has a last sentence pertaining to vehicles over 80 inches been omitted:
A written reply is not required. A phone call would be satisfactory.
Sincerely,
W. L. Hammer, P.E. Equipment Engineer (414) 259-4152