Interpretation ID: nht74-1.30

DATE: 02/15/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maserati, S.p.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 22, 1974, asking whether paragraph S4.3.1 of Motor Vehicle Safety Standard No. 108 precludes the mounting of rear lamps in a transparent "Lexan" panel "not involved in the driver's rearward vision."

Paragraph S4.3.1 states in pertinent part that ". . . each lamp . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair . . . ." The "glazing" referred to is the glazing regulated by Standard No. 205, and refers generally to glazing used in windshields, windows, doors, and interior partitions. Accordingly, Standard No. 108 does not preclude the mounting of rear lamps in the "Lexan" panel.

Yours truly,

ATTACH.

OFFICINE ALFIERI MASERATI S.p.A.

January 22, 1974

National Highway Traffic Safety Administration -- Office of Chief Counsel;

Attention: Mr. Vinson

Subject: Request for clarification of MVSS No. 108, Paragraph S.4.3.1.

Gentlemen:

Since we are planning to introduce soon in the United States our new model, the "KHAMSIN" (model 120), we would very much appreciate your clarifying the intent of paragraph S.4.3.1. of Motor Vehicle Safety Standard No. 108 -- "Lamps, Reflective Devices and Associated Equipment."

Paragraph S.4.3.1 of MVSS No. 108 states that "each lamp . . . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair, . . .".

As you will see in the enclosed documents, the "KHAMSIN" is a two door GT coupe which embodies, as a new styling concept, a rear end panel made of transparent "Lexan" material. The two rear combination lamps are securely mounted on this Lexan panel.

The Lexan material is a polycarbonate sheet, produced by the General Electric Company under the designation "LEXAN MR-4000". It is especially treated on both sides in order to make it scratch resistant. It is completely collision proof and is classified by the "Underwriters' Laboratories Inc." as the sole transparent antilock-picking material.

The mounting of the rear combination lamps on the rear end panel is described in the enclosed blueprint No. 120 VS 83090 and shown on the 2 enclosed B & W photographs.

This tansparent rear end panel is not involved in the driver's rearward vision and it is transparent only for aesthetic purposes. It is permanently mounted on the vehicle and its replacement constitutes a major repair.

We believe that paragraph S.4.3.1 of Standard No. 108 was intended to prevent mounting of lamps on glazing material which concurs to the driver's vision (such as windows), but since the wording of this paragraph is not clear to us, we would appreciate very much your clarifying if mounting the rear lamps such as it is done on the KHAMSIN does comply with MVSS No. 108.

Thanking you very much in advance for a prompt answer, we remain at your disposal should you need more information on this matter.

Very truly yours,

Bernard Belier -- U.S. Resident Engineer for MASERATI S.p.A.