Interpretation ID: nht94-3.74

TYPE: INTERPRETATION-NHTSA

DATE: July 19, 1994

FROM: P. Binder -- ITT Automotive Europe GmbH

TO: John Womack -- Office of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 8/2/94 from John Womack to P. Binder (Std. 108)

TEXT: Dear Mr. Womack,

Thank you for your reply of June 21, 1994.

To my regret I was forced to realize that I had made a mistake. My fax of April 28, 1994 should be referred to tail lamps.

Lighting System:

[ILLUSTRATION OMITTED - SEE ORIGINAL SOURCE]

1. With regard to the tail lamps I interpret FMVSS 108 and SAE J 585e, Sept. 77 as follows:

- This Lighting System is a multiple lamp arrangement, therefore the combination of taillamp 1 and taillamp 2 has to be used to meet the photometric requirements for 2 lighted sections (SAE J 585e; 3.1 and Table 1).

2

- Visibility will be judged with tailgate closed. Only taillamp 2 mounted on the tailgate will meet the requirements for an unobstructed projected illuminated area of 12,5 cm' measured at 45 deg inboard. This is in accordance with SAE J 585e; Par. 4.

Is my interpretation o.k.?

2. Some general questions:

- Are there regulations, which lamps has to be mounted on the body and which lamps are allowed on the tailgate?

Is there a regulation to take an approval test in an authorized test laboratory (e.g. ETL)?

- Which US-Authority has to be informed about this test?

- How long is this test valid?

- After which period has this test to be repeated?

Excuse my thoughtlessness. Please reply as soon as possible by fax (Fax-No.: Germany - 7142 - 73 28 95). Thank you very much in advance.