Interpretation ID: nht68-2.2

DATE: 06/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 31, 1968, to Mr. George C. Hield, concerning your combination stop, tail, and turn signal lamp.

You are correct in your interpretation with respect to the combination lamp (A,B,C) fulfilling the requirement of paragraph S3.3 (a) of Motor Vehicle Safety Standard No. 108. However, the additional tail lamp (C) must also conform to the requirement of paragraph S3.1.2 which specifies that no additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment. If the intensity of tail lamp (C) is extremely high, the lamp could impair the effectiveness of lamp combination (A,B) when the combination is used as a stop or turn signal lamp. As you noted, the intensity of the tail lamps may be reduced by inserting resistance in the tail lamp circuit as provided by SAE Standard J585c.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.