Interpretation ID: nht88-1.50

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/88

FROM: M. IWASE -- MANAGER TECHNICAL ADMINISTRATION DEPT. KOITO MFG. CO., LTD.

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: INSTALLATION OF TAIL & STOP LAMP ONTO MOVING VEHICLE PART

ATTACHMT: ATTACHED TO LETTER DATED 09/15/88 TO M. IWASE FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108; LETTER DATED 07/30/80 TO DIETMAR M HAENCHEN FROM FRANK BERNDT

TEXT: Dear Sir;

Thank you for your kind consideration which you have extended to us.

We, Koito Mfg. Co., Ltd., would like you to advise us about the tail & stop lamp as shown below;

(DRAWING OMITTED)

1. Lamp "A" having function of tail & stop lamp is fitted onto the moving vehicle part (trank lid, etc.).

2. Lamp "A" meets the min./max. values for both functions of tail & stop specified in FMVSS No. 108 at a design attitude when the moving part is closed.

It is designed that vehicle be driven with its trank lid closed. Therefore, Lamp "A" installed on moving part should be permissible, we think.

Question:

1. Whether such a tail & stop lamp fitted onto moving vehicle part could be permissible or not under FMVSS No. 108.

2. If Lamp "A" is turn signal lamp instead of tail & stop lamp, how about the permission under FMVSS No. 108.

Again, thanking you and awaiting your prompt reply, we remain,

With our best regards,

Yours very truly,