Interpretation ID: nht75-2.46
DATE: 06/09/75
FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA
TO: Wesbar Corporation
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of May 13, 1975, requesting an interpretation of paragraph S4.4.1 of Motor Vehicle Safety Standard No. 108 as it applies to a described lamp design.
In pertinent part, S4.4.1 states that "no clearance lamp may be combined optically with any taillamp." The lamp design that interests you has separate compartments for the taillamp and for the clearance lamp. You are concerned that at a distance it will be difficult to distinguish the two lamps, and you feel that this violates the spirit of S4.4.1.
We have no objection to the design of this lamp. Since the clearance lamp and taillamp are in separate compartments and not optically combined, and since Standard No. 108 does not specify a minimum separation distance between the two lamps, the lamp design does not violate S4.4.1.
SINCERELY,
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May 13, 1975
Richard B. Dyson, Active Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration
Wesbar Corporation is a manufacturer of lights, primarily used on boat trallers and utility trallers. We have received from a number of our customers an inquiry as to the possibility of making a tall light similar to the attached sketch, which would serve then as a tall light, stop light, turn signal, reflex reflector, and clearance light.
We have taken the position that a light of this type would not meet the spirit of DOT 108, paragraph S 4.4.1, which states, "Two or more lamps, reflective devices, or items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, except that no clearance lamp may be combined optically with any tall lamp or identification lamp."
A light of the design we indicate on the enclosed drawing would include a separate compartment for the tall, stop and turn light and a separate compartment for the clearance lamp. However, at a distance of 30 or 40 feet to the rear of the vehicle, it would be very difficult to make a distinction between the tall light and the clearance lamp, except possibly by doing some design work on having a different configuration to the lens on the clearance lamp.
We do not wish to be in the position of second guessing your department's interpretation of S 4.4.1 and would therefore appreciate your comments and interpretation of that section. On receipt of same, we will send a copy of this interpretation to the manufacturers who have made these inquires of us.
Your early attention in this matter will be very much appreciated.
WESBAR CORPORATION
Bernard R. Weber Executive Vice President
SINGLE HOUSING WITH SEPARATE COMPARTMENTS FOR EACH LIGHT
TAIL, STOP & TURN SIGNAL LIGHT
CLEARANCE LIGHT
CLASS "A" REFLEX REFLECTOR
1/8" APPROX. BETWEEN ALL LENSES
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