Interpretation ID: nht88-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Automotive Safety Testing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Billy S. Peterson President Automotive Safety Testing, Inc. Product Liability-Testing-Certification at TRC of Ohio East Liberty, OH 43319

Dear Mr. Peterson:

This is in reply to your letter of September 23, 1987, with respect to positioning of rear mounted lamps and reflectors in accordance with Federal Motor Vehicle Safety Standard No. 108. Your client has designed a vehicle in which the backup lamps and rea r reflex reflectors would be mounted on the deck lid, and you have asked whether there are any current or contemplated prohibitions that would preclude this design.

The lamps in question will be mounted on a rigid part of the vehicle as required by paragraph @4.3.1 of Standard No. 108, and the deck lid will be closed and the lamps and reflectors in full view under normal operating conditions. The visibility requirem ents of lamps and reflectors in Standard No. 108 are predicated on the normal driving or closed deck lid position. Since the use of motor vehicles, including driving with deck lids open or otherwise having the lamps and reflectors obscured by a particula r load on the vehicle is under the jurisdiction of the individual States, we do not anticipate rulemaking on this subject. Thus, this design is not prohibited by Standard No. 108.

Sincerely, Erika Z. Jones Chief Counsel

September 23, 1987 Administration National Highway Traffic Safety U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Steed:

Our client, Hyundai Motor Company, has asked us to inquire regarding the positioning of rear mounted lamps and reflectors in accordance with FMVSS 108 for a new model currently in the final design stages. The rear lighting design for the new model provides for mounting some of the lighting on the bottom edge of the trunk lid, similar to a design currently used on the Audi 5000.

Although FMVSS 108 Table IV only calls for paired lamps and reflectors that are required on the rear to be at the same height on each side of the vertical centerline and "...as far apart as practicable," Hyundai would like to know if there are any curren t specific prohibitions or future anticipated changes that would preclude or limit the mounting of rear lamps or reflectors on the trunk lid. A schematic of the rear lighting configuration for the new model is enclosed.

Sincerely,

Billy S. Peterson President

BSP/PLS/plm

Enclosure