Interpretation ID: nht95-2.3

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: Takashi Adachi -- Manager, Ichikoh Industries, Ltd.

TO: Richard L Van Iderstin -- Visibility and Controls Group, Office of Vehicle Safety Standards, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/9/95 LETTER FROM JOHN WOMACK TO TAKASHI ADACHI (A43; STD. 108)

TEXT: Dear Mr. Van Iderstein,

I am writing this letter to ask you a view with regard to conformity of the reflex reflector included in rear lamp that our company are consider to design. Structure of design are described on the attachment.

My questions are related to conformity to FMVSS 108, as follows.

1. Does this structure of the reflex reflector conform to FMVSS 108? 2. Shall the reflex reflector meet the photometric performance requirement in the whole area of the reflex reflector? 3. Or shall each area (upper and lower) of the reflex reflector meet the photometric requirement individually?

Thank you in advance, I will call you later to listen your reply.

Enclosed: figure 1 (rear of lamp) shows clear and red outer lens, reflex reflector and opaque area. (Figure omitted.)