Interpretation ID: nht90-3.41

TYPE: Interpretation-NHTSA

DATE: August 1, 1990

FROM: Rickey Bass -- Q.C. Manager, Terminal Service Co.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re High mounted stop lamp and identification lamp combination.

ATTACHMT: Attached to design drawing of lamp (graphics omitted); Also attached to letter dated 9-24-90 from P.J. Rice to R. Bass (A36; Std. 108)

TEXT:

Terminal Service Company would like to have your office give us a written interpretation of the current laws, to see if they would prohibit the use of a combination stop and identification lamp. The combination lamp in question would be used on Departme nt of Transportation certified cargo tank motor vehicles.

We realize that FMVSS 108 prohibits combining other clearance lamps with any tail or identification lamp. But, it also says that two or more lamps or reflective devices, and items of associated equipment may be combined if the requirements for each item and associated equipment are met. FMVSS 108 also states the manufacturer is to determine if the function of the equipment is impaired.

Our stop and identification lamp would consist of three (3) separate single compartments, each having its own lens and dual filament bulb, located at the specified location for the identification lamp. A design drawing is enclosed for the purpose of ill ustration.

Terminal Service Company feels that with this design, the function of the identification light, at the rear of the cargo tank will be intact, although when the brake light is illuminated, the identification light will be brighter.

Your assistance would be appreciated.