Interpretation ID: nht72-2.32

DATE: 01/13/72

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Joseph Lucas North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 23, 1971, to Mr. J. E. Leyseth of this Office in which you asked if each reflex area in a two-section reflector separated by a side marker lamp needs to meet the photometric requirements of a Class A reflector.

Each reflex area need not meet the photometric requirements for a Class A reflex reflector provided that when the areas are combined they meet the photometric requirements, and provided further, that the marker lamp lens is included in the maximum exposed area of 12 sq. in. contained within a 7 in. diameter circle per SAE J594d.