Interpretation ID: nht71-4.38

DATE: 11/02/71

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your recent telephone inquiry as to whether the recent amendment of Standard 215, Exterior Protection, requires that vehicles meet the photometric requirements of Standard 108 after being subjected to the Standard 215 impacts.

S5.3.1 of Standard 215 reads:

"Each lamp or reflective device, except license plate lamps, shall be free of cracks and shall comply with the applicable requirements of Motor Vehicle Safety Standard No. 108."

S4.3.1.1 of Standard 108 reads in relevant part:

"Each lamp and reflective device shall be located so that it meets the visibility requirements specified in any applicable SAE Standard or Recommended Practice. In addition, no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard or Recommended Practice." (Emphasis supplied.)

Thus, although the actual photometric tests may be considered "bench tests", that is, tests whose procedures include removing the devices from the vehicle, the above provision of Standard 108 requires that the configuration of the vehicle external to the devices not prevent them from meeting the photometric requirements. The test procedures themselves require the devices to be placed

in their actual orientation on the vehicle. Therefore, the provision in Standard 215 that the lamps and reflective devices shall meet all the requirements of Standard 108 after the impacts includes the photometric requirements.