Interpretation ID: nht79-1.18

DATE: 04/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Alfa Romeo, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. D. Black, Manager U.S. Engineering Office Alfa Romeo, Inc. 250 Sylvan Avenue Englewood Cliffs, New Jersey 07632

Dear Mr. Black:

This is in reply to your letter of March 12, 1979, to Mr. Vinson of this office asking for an opinion of whether a red rear fog lamp system would be permissible under Federal Motor Vehicle Safety Standard No. 108 as original equipment. This lamp system would be of the same intensity as the stop lamp system, installed in a separate compartment within the rear lamp assemblies. The system would have a separate switch and be operational only when the headlamp switch is in the "On" position.

As you have noted, Standard No. 108 does not specify requirements for either front or rear fog lamps. Lighting equipment supplementary to that required as original equipment may be provided at the manufacturer's option if it does not impair the effectiveness of any equipment installed in accordance with Standard No. 108 (S4.1.3). On the basis of your submission, we are unable to form an opinion whether your system would impair effectiveness within the meaning of S4.1.3. If it is Alfa Romeo's judgment that the red fog lamps will not impair the effectiveness of the taillamps, stop lamps, turn signal lamps or backup lamps, then you may have a reasonable basis upon which to install the fog lamp system and to certify compliance with S4.1.3.

Sincerely,

Frank Berndt Acting Chief Counsel

Alfa Romeo, Inc.

March 12, 1979 Ref. Nr. 068

Dear Mr. Vinson:

FMVSS 108 is lacking in the area of non specified lighting devices, and we find it necessary to request your interpretation of the standard itself.

We would like to incorporate into our rear light assemblies a rear red fog lamp of the same intensity of the present stop lamp. The fog lamp would be installed in a separate compartment within the rear lamp assembly. This compartment having its own lens and reflector. We propose to use a separate switch with warning light for operation of this fog lamp. It would only be operational when the headlamp switch is in the "on" position.

We feel this system has merit for U.S. model Alfa Romeo vehicles. For the same reason, it is standard on our European models. However, FMVSS 108 is absent of any reference to such a device. One could, but its absence, assume it is either permissible or forbidden. We think that the intent of 108 is to permit the use of such non specified safety features.

Could you please discuss this with one of your 108 experts and let us know your combined opinions as to its compliance status.

A diagram of the tail lamp assembly indicating the desired location for such a device in the as yet unoccupied compartment is enclosed.

Sincerely yours,

D. Black