Interpretation ID: 1985-04.14

TYPE: INTERPRETATION-NHTSA

DATE: 11/04/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo, 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of September 19, 1985, to the former Chief Counsel of this agency, Frank Berndt, asking for an interpretation of paragraph S4.1.3 of Motor Vehicle Safety Standard No. 108.

This paragraph forbids the installation of lamps and reflective devices other than those specified by the standard, as well as other types of motor vehicle equipment, if such will impair the effectiveness of the lighting equipment that the standard requires. You have asked if this prohibits the installation of any lamp that is not specified by the standard, and if there are any restrictions for the color, mounting location, or luminous intensity. You ask this with reference to "a decorative extra lighting device".

Paragraph S4.1.3 does not prohibit the installation of lighting devices not required by the standard. There are no restrictions covering the areas that interest you. Whether a "decorative extra lighting device" would be prohibited by S4.1.3 would, of course, be determined by its size, shape, luminous intensity, proximity to required lighting equipment, etc. but in the absence of a description of your device we cannot offer an opinion as to whether it would conflict with S4.1.3.

Sincerely, Erika Z. Jones Chief Counsel

September 19, 1985

Att.: Mr. Frank Berndt Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U. S. A.

Re: Installation of decorative extra lighting device to the vehicle, which is not specified in FMVSS No.l08

Dear Mr. Berndt,

We are thinking of producing a decorative extra lighting device, which will be mounted on the rear side of motor vehicle. FMVSS mentions about such lighting device, as below.

FMVSS N0.108, Paragraph 4.1.3 -

No additional lamp, reflective device, or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard.

Does this paragraph mean that any lamp which is not specified in Regulation, shall not be mounted on the motor vehicle? If there is any restriction for the color, mounting location, luminous intensity for the decorative extra lighting device, including reflex reflective device, please let us know.

We are looking forward to your quick reply.

Very truly yours, Stanley Electric Co., Ltd.

T. Chikada, Manager, Automotive Lighting Engineering Control Dept.