Interpretation ID: nht88-1.46
TYPE: INTERPRETATION-NHTSA
DATE: 02/19/88
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Stanley Electric Co.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. M. Arisaka Manager, Automotive Lighting Engineering Dept. Stanley Electric Co. Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153 JAPAN
Dear Mr. Arisaka:
This is in reply to your letter of September 23, 1987, with respect to daytime running lamps (DRLs).
With reference to the Canadian proposal on this subject, you have noted that it would allow optically combining the DRL with the parking lamp, using dual intensity bulbs within the same housing and covered by the same lens. (As you may be aware, the Cana dian government recently issued a final rule which adopted the proposal). You have further noted that the maximum candela output of the parking lamp together with the candela of the DRL will be greater than the maximum permitted for the parking lamp. You believe that under this circumstance the parking lamp does not have to conform to the maximum values specified, and have asked for our opinion of this matter.
Under the proposal by the United States, a DRL would have to be a lamp other than a parking lamp (proposed new paragraph S4.6.3(a)), because their brightness is inadequate for use as DRLs. However, the DRL could be incorporated into a multiple function l amp, one of whose functions is to serve as a parking lamp. A lamp with multiple functions must meet all requirements that apply when a specific function is being fulfilled. For example, a lamp that functions both as a parking lamp and a DRL and which is operated in daylight could act as either a DRL or a parking lamp, depending on the intensity of the light emitted, but it would have to meet the photometric requirements for the function being exercised. We cannot really be more specific in answering you r questions, because we are still at the proposal stage of the rulemaking process. The final decision could differ.
Sincerely,
Erika Z. Jones Chief Counsel
September 23, 1987
Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 900 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.
Re. Daytime Running Lamp in the United States
Dear Ms. Jones,
Proposal of Daytime Running Lamp was issued in Canada. In this proposal, Daytime Running Lamp can optically combined with Parking Lamp using same housing and lens with dual intensity bulbs.
We would like to ask you following question on this combined DRL.
-Question-
On this combined DRL with Parking Lamp, DRL and Parking Lamp should be lit simultaneously when switch of Parking Lamp is "ON" position.
In that condition, maximum value of Parking Lamp together with DRL will be greater than the required maximum value of Parking Lamp.
Since, present FMVSS No.108 does not prescribe on DRL, it may be interpreted that the measured maximum value of Parking Lamp can not conform with the required maximum value of FMVSS No.108.
We think that Canadian made passenger car which equips with the combined DRL will go to the United States, in that case the Parking Lamp does not have to conform the required maximum value of FMVSS No.108.
We would like to ask you to give us NHTSA's opinions on this matter.
We appreciate for your quick reply.
Sincerely yours,
Stanley Electric Co., Ltd.
M. Arisaka Manager, Automotive Lighting Engineering Sect.