Interpretation ID: nht79-1.36

DATE: 11/23/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

NOV 23 1979

Mr. T. Fujita Manager, Automotive Lighting Engineering Department Stanley Electric Co., Ltd 2-9-13, Nakameguro Meguro-ku Tokyo 153, Japan

Dear Mr. Fujita:

This is in reply to your letter of October 17, 1979, asking for an interpretation for Paragraph S4.3.1.7 of Federal Motor Vehicle Safety Standard No. 108.

S4.3.1.7 says in effect that a front turn signal lamp and a low beam headlamp may be closer to each other than 4 inches "if the sum of the candlepower values of the turn signal lamp measured at the test points within each group listed in Figure 1 is not less than two and one-half times the sum specified for each group for yellow turn signal lamps."

You have asked whether a motorcycle turn signal lamp should "satisfy the values specified in S4.3.1.7 or half those values. The answer is, the values specified in S4.3.1.7. Half those values would be "less than two and one-half times the sum specified ..." and impermissible under S4.3.1.7.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel October 17, 1979

Att.: Mr. Michael M. Finkelstein Associate Administrator for Rulemaking

U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590 U. S. A.

Re: Photometric requirement of a motorcycle front turn signal lamp which is mounted closer to the low beam headlamp than 4 inches.

Dear Mr. Finkelstein,

Section 4.3.1.7 of FMVSS No.108 specifies as follows;

S.4.3.1.7

The requirement that there be not less than 4 inches between a front turn signal lamp and a low beam headlamp, specified in SAE Standard J588e, "Turn Signal Lamps," September 1970, shall not apply if the sum of the candlepower values of the turn signal lamp measured at the test points within each group listed in Figure 1 is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.

When we apply this provision to a motorcycle turn signal lamp, we would like to have your opinion as to which one of the following requirements the lamp should satisfy.

A: the values specified in S.4.3.1.7

B: half the values of that specified in S.4.1.3.1.7

Thanking you in advance for your cooperation,

Very truly yours,

Stanley Electric Co., Ltd.

T. Fujita Manager, Automotive Lighting Engineering Dept.

MF/mo