Interpretation ID: GF007569-2

Mr. Robert Strassburger
Vice President, Safety and Harmonization
Alliance of Automobile Manufacturers
1401 H Street, NW, Suite 900
Washington, DC 20005

Dear Mr. Strassburger:

This responds to your letter asking us to reconsider our May 22, 2003, interpretation letter to Mr. Babcock of Hyundai concerning whether a multi-component rear reflex reflector configuration would comply with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. The issues raised by your letter are addressed below.

Table III of Standard No. 108 requires that each passenger car (and certain other specified vehicles) be equipped with 4 red and 2 amber reflex reflectors. Table IV of the standard requires that two red reflex reflectors be located on the rear of the vehicle, one on each side of the vertical centerline, and as far apart as practicable. The applicable photometry requirements for reflex reflectors are incorporated by reference from SAE J594f, "Reflex Reflectors," January 1977.

In our letter to Mr. Babcock, we addressed a rear reflex reflector configuration which consisted of three separate reflex reflectors. One reflector was installed on the fender and a second reflector was located adjacent to it, on the deck lid. The third reflector was hidden by the deck lid and was not visible until the deck lid was raised. No single reflector fulfilled the photometric requirements for a rear reflex reflector, but these requirements were met when the reflector on the fender and either of the other two reflectors were measured.

We explained that this design was not a permissible configuration under Standard No. 108. We stated that the text and setup for testing set forth in SAE J594f clearly indicate that the requirements of this standard apply to a single reflex reflector, and may not be met using a combination of separate reflex reflectors.

In requesting reconsideration, you state that our interpretation is potentially inconsistent with a prior interpretation of Standard No. 108, sent to Mr. Bataini of DBM Reflex Enterprises on July 19, 2000. In that interpretation, we addressed a configuration where side mounted reflective devices were incorporated into a headlamp housing and visible from the side when light is reflected from them. We stated that the relevant question was "whether Standard No. 108 permits a front side marker reflector to consist of two reflective devices molded separately and assembled on the same housing." We concluded that the answer is yes, provided that when assembled they meet the requirements of SAE Standard J594f.

You suggest that the standard should be interpreted to "permit a reflex reflector to consist of two (or more) reflective devices molded separately and installed on a single, rigid part of the vehicle (such as the fender or bumper) as long as the devices are mounted closely enough together that they meet the test requirements of SAE J594f." You noted that SAE J594f allows reflex reflectors to "have any linear or area dimensions," as long as the photometric performance is met with a specified maximum projected area contained within a 10 inch diameter circle.

We are pleased to clarify Standard No. 108s requirements for reflex reflectors. After considering your letter, it continues to be our opinion that for each reflex reflector required by the standard, all of the standards requirements for that reflex reflector must be met by a single reflex reflector.

We interpret the word "reflector" to refer to a single reflector, that must fully comply on its own. In other situations where Standard No. 108 allows the requirements for an item of lighting equipment to be satisfied by more than one item, it explicitly says so. See, e.g., section 3.1 of SAE J585e (tail lamps), section 5.1.5.2 of SAE J586 (stop lamps), and section 5.1.5.2 of SAE J588 (turn signal lamps). (These SAE recommended practices are incorporated by reference in Standard No. 108.)

We do not believe there is any inconsistency between our letters to Mr. Babcock and Mr. Bataini. In our letter to Mr. Bataini, we addressed the issue of "whether Standard No. 108 permits a front side marker reflector to consist of two reflective devices molded separately and assembled on the same [headlamp] housing."(Emphasis added.) We were not addressing the issue of multiple reflectors.

We note that Standard No. 108 does not specify that all of the reflective elements of a reflex reflector need to be contiguous. Our view when we issued the letter to Mr. Bataini was that whether the reflective elements of the reflex reflector were molded to each other and then mounted on a headlamp housing, or instead separately mounted on the headlamp housing, the finished product was a single item (both a single reflector and a combination lamp). By contrast, multiple unconnected reflective devices installed on the vehicles fender or bumper would not constitute a single reflector.

Finally, we note that the use of multiple reflectors in place of a required single reflector would not only raise testing issues but also concerns related to replacement of broken reflectors. Standard No. 108 specifies requirements only for single reflectors. If a vehicle manufacturer used multiple reflectors in place of a single reflector, there would be no way of knowing the apportioned contribution of each of the separate reflectors. It would be difficult, if not impossible, for an aftermarket manufacturer to supply parts that have the same reflectivity as the original parts, and there would be certification problems for these manufacturers. Therefore, if one of the separate reflectors became broken and the vehicle owner replaced it (but not all of the reflectors), the vehicle might not provide the minimum required performance in this area.

I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

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