Interpretation ID: nht79-1.14

DATE: 10/04/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Grote Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT:

October 4, 1979

Mr. C. J. Newman Vice President, Engineering The Grote Manufacturing Company State Rt. 7 - P.O. Box 766 Madison, Indiana 47250

Dear Mr. Newman:

This in reply to your letter of August 23, 1979, to the former Chief Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp "meets the intent" of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.

You have quoted paragraph 3.4 of SAE Standard J588e, September 1970, which states "the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles." It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.

We would also like to observe that since the side marker signal uses the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.

Sincerely,

Frank Berndt Chief Counsel

Mr. Taylor Vinson Office of the Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATlON 400 Seventh Street S W WASHINGTON DC 20590

September 24, 1979

Dear Mr. Vinson

Request for Interpretation

In the case of a motorcycle headlamp, Table III of FMVSS 108 cites SAE J584, which in turn specifies that for photometric tests, the "bulb or unit shall be operated at its rated voltage during the test."

Where the material bulb is an H1, H2, H3 or H4 halogen bulb that bears the E-mark signifying that it is in compliance with E/ECE/TRANS/505/Rev.1/Add.36, that is to say in compliance with Regulation 37 of the Geneva Agreement of 20 March 1958 as adopted by the general European governments, is the rated voltage required by SAE J584 the same rated voltage of ECE Regulation 37?

Yours sincerely

H J T YOUNG Vice President - Technical Affairs

E/ECE/324 ) E/ECE/TRANS/505 )Rev.1/Add.36 Regulation No. 37 Annex 1 page 21/22

CATEGORY H4 Sheet H4/2

Characteristics

Lamps of normal production Standard lamps

*Insert chart here

1/ Where a yellow outer bulb is used, "m" and "n" denote the maximum dimensions of this bulb; where there is no outer bulb "m" denotes the maximum length of the lamp.

2/ It must be possible to insert the lamp into a cylinder of diameter "s" concentric with the reference axis and limited at one end by a plane parallel to and 20 mm distant from the reference plane and at the other end by a hemisphere of radius S/2.

3/ The obscuration must extend at least as far as the cylindrical part of the bulb. It must also overlap the internal shield when the latter is viewed in a direction perpendicular to the reference axis. The effect sought by obscuration may also be achieved by other means.

4/ The values indicated in the left-hand column relate to the driving beam. Those indicated in the right-hand column relate to the passing beam.

August 23, 1979

U. S. Department of Transportation NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attn: Mr. J. J. Levin, Jr. Chief Counsel

Dear Sir:

We are considering certain revisions to our line of front double-faced pedestal mount turn signal lamps. Before making any commitment to our customers or before making any tool changes, we need your opinion as to whether the lamp meets the requirements of Federal Motor Vehicle Safety Standard 108.

In the past, double-faced turn signal lamps having side marker devices have normally been manufactured with two bulbs -- a 1156 or 32 candle power bulb functioning as the turn signal system, and a 2 or 3 candle power bulb functioning as the side marker device. In this case, having an yellow lens to the front and a red lens to the rear. Our proposed change is to use one 1157 bulb, dual function 32 - 3 candle power filaments where the 32 candle power filament is used as the turn signal function and the 3 candle power is used as the side marker device. In order to do this, a yellow lens to the front, yellow lens to the rear is required and also the baffling inside of the double-faced lamp has to be reduced in order to meet the side marker requirements. With this particular design, all three lenses -- the lens to the front, to the rear and to the side -- function as part of the side marker device.

The question that we have is the intent of rulemaking covering turn signal lamps. The turn signal lamp, SA J588e, last revised September, 1970, includes Item 3.4 which states, "The flashing signal from a double-faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles."

With the baffling area reduced inside of the lamp as indicated by the sample, and since the requirements are very subjective, we need an opinion as to whether the lamp does or does not meet the intent of Federal Motor Vehicle Safety Standard 108.

Would you please review the sample and give us your opinion as soon as possible.

Yours very truly,

THE GROTE MANUFACTURING COMPANY

C. J. Newman Vise President, Engineering

CJN/aj