Interpretation ID: nht90-3.18

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: S. Watanabe -- General Manager, Automotive Equipment Technical Coordination Dept., Stanley Electric Co., Ltd.

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to S. Watanabe (A36; Std. 108)

TEXT:

We would like to ask you a question about a configuration of combination rear lamp which fulfils both tail and rear side marker functions as sketched below.

(Graphics omitted)

In accordance with the requirement of S.5.5.7 of FMVSS No. 108, the two functions (ie. Tail & Side marker) are presented at the same time. Thus the light output of side marker lamp is also emanated toward the rear of the vehicle mixed with tail lamp ligh t, and similarly, the light output of tail lamp is also emanated toward the side mixed with side marker lamp light.

Please let us have your answers to the following questions.

1) Should the Tail lamp function of this lamp meet the photometric requirements for 2 lighted sections, or 3 lighted sections?

2) Should the Side marker function of this lamp meet the photometric requirement of SAE J592e by 3 lighted sections or 1 lighted section?

I greatly appreciate receiving your reply to the above as soon as possible.