ID: aiam4773

Dear Herr Westermann: This is in reply to your letter to Dr. Burgett o this agency with respect to 'multi bulb devices', specifically 'how the requirements for one-, two-, or three compartment lamps (lighted sections) as it is documented in FMVSS No. 108, Figure lb have to be interpreted. . . .' You have asked this question because 'Hella would like to equip motor vehicles with signalling devices which have --opposite to conventional lamps--a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb.' Your question assumes that Standard No. 108 is to be interpreted in a manner that equates the number of lighted sections with the number of bulbs providing the light. Finally, you have stated that the total area of the lamp is not larger than current one-compartment lamps. We regret the delay in responding to your letter, but we have recently completed rulemaking, begun in September l988, which is relevant to your question. On May 15, l990, an amendment to Standard No. 108 was published, effective December 1, l990, the effect of which is to restrict Figure 1b to replacement equipment. I enclose a copy of the amendment for your information. Your question relates to 'signalling devices' for new motor vehicles, and Figure 1b shows that, specifically, you refer to turn signal lamps. Beginning December l, l990, Standard No. 108 will specify two different standards for turn signal lamps. If the lamp is intended for use on multipurpose passenger vehicles, trucks, buses, and trailers whose overall width is 80 inches or more, it must be designed to conform to SAE Standard J1395 APR85 Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. SAE J1395 also provides that these lamps may be used on vehicles less than this width, except for passenger cars. If a motor vehicle is not equipped with a turn signal lamp designed to conform to SAE J1395, it must be equipped with a turn signal lamp designed to conform to SAE Standard J588 NOV84 Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width. In the May l990 amendments, section S3 of Standard No. 108 was amended to add a definition for 'Multiple Compartment Lamp'. Such a lamp is 'a device which gives its indication by two or more separately lighted areas which are joined by one or more common parts, such as a housing or lens.' The multiple bulb device that you described appears to meet this definition. SAE J1395 establishes luminous intensity minima and maxima photometric requirements without reference to either compartments or lighted sections, and all that is required is for the lamp to comply at the individual test points specified. New section S5.1.1.31 clarifies that measurements of a multiple compartment turn signal lamp on vehicles to which SAE J1395 applies are to made for the entire lamp and not for the individual compartments. However, SAE J588 NOV84 continues to specify different minimum photometric requirements for one, two, and three 'lighted sections'. Because the SAE does not prescribe photometric requirements for more than three lighted sections, we have concluded that any device that contains more than three lighted sections need only comply with the requirements prescribed for three lighted sections. I hope that this is responsive to your request. Sincerely, Paul Jackson Rice Chief Counsel;

ID: aiam4948

"Dear Mr. Rogers: This responds to your request that this agenc determine that the new antitheft device to be installed on the MY 1992 General Motors Pontiac Bonneville line, represents a de minimis change in the system that was the basis for the agency's previous granting of a theft exemption for the car line beginning in MY 1991, and that therefore the Pontiac Bonneville vehicles containing the new device would be fully covered by that exemption. The agency has reviewed the changes to the system and for the following reasons concludes that the differences between the original system and one installed on the MY 1992 Pontiac Bonneville constitute a de minimis change. As you are aware, the Pontiac Bonneville car line was granted an exemption, pursuant to 49 CFR Part 543, from antitheft marking because General Motors showed that the antitheft device to be used in lieu of marking on the car line was likely to be as effective as parts marking. This antitheft device is known as the 'PASS-KEY' antitheft system. The exemption was issued on April 4, 1991, and appeared in the Federal Register on April 9, 1991 (56 FR 14413). As was stated in the April 1991 Federal Register notice, the 'PASS-KEY' antitheft system utilizes an ignition key, an ignition lock cylinder and a decoder module. Before a vehicle can be started, the electrical resistance of a pellet embedded in the shank of the key must be sensed by elements in the lock cylinder and its value compared to a fixed resistance in the decoder module. In your letter, it was stated that beginning from MY 1992, two design changes were made in the 'PASS-KEY' antitheft device that is standard equipment on the Pontiac Bonneville. The new system on the Bonneville is known as 'PASS-KEY II,' and differs from 'PASS-KEY' as follows. First, in 'PASS-KEY II,' if a key other than the one with proper resistance for the vehicle is inserted, the decoder module will shut down the fuel injector pulses to the engine for three minutes plus or minus eighteen seconds. In 'PASS-KEY,' this shut down period is two to four minutes. Second, if, during the time the decoder module has shut down in 'PASS-KEY II,' trial and error attempts are made to start the engine with various keys, the timer will not reset to zero, as is the case with 'PASS-KEY.' GM states that this difference in functions will provide a similar level of performance as 'PASS-KEY' since the 'PASS-KEY II' module, while shut down, will ignore further attempts to start the system by means other than use of a key with the proper resistance pellet. Any further unauthorized attempt after the initial three minute shut down time will result in the module shutting down again. After reviewing the proposed changes to the componentry and performance of the antitheft device on which the exemption was based, the agency concludes that the changes are de minimis. In addition to providing some aspects of performance not provided by the original device, 'PASS-KEY II' also continues to provide the same aspects of performance provided by the original device and relies on essentially the same componentry to provide that performance. Therefore, it is not necessary for General Motors to submit a petition to modify the exemption pursuant to 49 CFR Part 543.9(c)(2). If General Motors does not implement the new antitheft device as described in your letter for MY 1992, we request that this agency be notified of such decisions. Sincerely, Barry Felrice Associate Administrator for Rulemaking /";

ID: 17690.ztv

Mr. William A. Parkyn
Teledyne Lighting & Display Products
12525 Daphne Avenue
Hawthorne, CA 90250

Dear Mr. Parkyn:

This is in reply to your letter of March 20, 1998, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 with respect to stop lamps for motor-driven cycles.

Paragraph S5.1.1.22 of Standard No. 108 states in pertinent part that a motor-driven cycle may be equipped with a stop lamp whose photometric output "for the group of test points specified in Figure 1 is at least one-half of the minimum values set forth in that figure." Table III specifies that motorcycle stop lamps shall meet SAE Standard J586. You ask for confirmation that S5.1.1.22 "means that motor-driven cycle stop lamps must meet one half of the minima set forth in SAE Standard J586."

The minimum allowable candlepower value for a stop lamp is established by Figure 1b. For a single compartment stop lamp, this is 80 candlepower. Rather than determining photometric compliance through measuring candlepower at each individual test point, Figure 1c groups the individual test points into five Zones. Figure 1c is titled "Sum of the Percentages of Grouped Minimum Candlepower." The sum of the percentages for Zones 1 and 5 is 65 percent. The minimum allowable candlepower value for Zones 1 and 5 is determined by multiplying the minimum value of Figure 1b by the Zone percentage in Figure 1c, that is to say 65 percent of 80 candlepower, which is 52 candlepower. Under S5.1.122, then, at least half this value must be met by a motorcycle stop lamp, that is to say, Zones 1 and 5 must achieve at least 26 candlepower. The corresponding value established by SAE J586 is only 25 candlepower. For this reason, it is not correct to say that S5.1.1.22 means that motor-driven cycle stop lamps must meet one-half the minima set forth in SAE J586. However, this is a true statement for Zones 2, 3, and 4 where the values under both Figure 1 and SAE J586 are 100, 380, and 100 candlepower respectively.

In our review of your letter, we find that S5.1.1.22 could be more clearly expressed, and should read that the "photometric output for any group of test points specified in Figure 1c is at least one-half of the minimum value obtained when the minimum allowable stop lamp candlepower value of Figure 1b is multiplied by the appropriate percentage for the group that is specified in Figure 1c."

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/1/98

ID: aiam0980

Dear Mr. Long: This is in reply to your letter of January 30, 1973, concerning acryli headlamp covers.; Federal Motor Vehicle Safety Standard No. 108 incorporates Society o Automotive Engineers (SAE) Standard J580a, which prohibits the use of acrylic headlamp covers as original equipment. The requirements of SAE Standard J580a have also been incorporated in a number of State regulations, which are applicable to vehicles in use. Copies of Standard No. 108 and SAE Standard J580a are enclosed for your information.; A Notice of Proposed Rule Making (Docket 69-19, Notice 3) on Standar No. 108 was issued on October 16, 1972. This Notice includes a provision for optional use of headlamp covers which conform to certain performance requirements. Such requirements are specified in paragraph S7.9 of the Notice (copy enclosed). Acrylic Industries Pty. Ltd. may be interested in commenting on this *proposed* revision of Standard No. 108. The closing date for comments is April 18, 1973.; If you have any questions on the enclosed documents, please do no hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam3696

Dear Mr. Alexander: This is in reply to your letter of April 8, 1983, following conversation with Mr. Vinson of this office, with reference to Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; You are concerned with the 'design to conform' language as it relate to headlamps, and have asked for an interpretation that it 'does not mean that every lamp produced is required to have every photometric point in.'; I am not certain what you mean by 'every photometric point in' However, a manufacturer is expected to design his headlamps so that each will meet the minimum photometric output in candela set forth by SAE J579C for each test point. The agency does not pursue random occasional photometric failures at individual test points. But if a manufacturer's products show a pattern of failures to meet the minimum at any individual test point, the agency could consider this as an indication that the headlamp was, in fact, not 'designed to conform'.; I hope this answers your question. Sincerely, Frank Berndt, Chief Counsel

ID: aiam2270

Dear PFC Phillips: This is in reply to your letter of April 8, 1976, asking about Stat laws applicable to fog lamps, driving lamps, and quartz-iodine halogen driving lamps.; The American Association of Motor Vehicle Administrators, 1828 Street, N.W., Washington, D.C. may be able to provide you answers with respect to State laws, as each State, rather than the Federal government, sets its own requirements for registration and use of motor vehicles within its borders.; The only aspect that you mentioned which we cover in our Federa vehicle lighting standard is the minimum and maximum height of headlamps above the road surface. These measurements are 24 inches and 54 inches respectively, measured from the center of the headlamp on the vehicle at curb weight. If a State has a law on maximum and minimum headlamp height it is required to be identical to this one. States may permit or prohibit fog lamps, driving lamps, and quartz-iodine halogen driving lamps as they choose since there are no Federal requirements for them.; Yours truly, Stephen P. Wood, Assistant Chief Counsel

ID: aiam1860

Dear Senator Talmadge: This responds to your recent communication requesting consideration o a constituent's concern about the National Highway Traffic Safety Administration's standard requiring antiskid devices on new school buses for all states, although some states do not often have icy roads.; The regulation to which your constituent Mr. Smith refers is Federa Motor Vehicle Safety Standard No. 121, *Air brake systems*. This standard which became effective for trailers on January 1, 1975, and trucks and buses on March 1, 1975, specifies minimum performance requirements for service brake systems, emergency brake systems, and parking brake systems utilized on air-braked vehicles. The standard does not specifically require antilock devices, although S5.3.1 of the standard does specify minimum stopping distance and stability requirements on dry and wet roads. Most vehicle manufacturers have decided to utilize antilock devices to meet these requirements. The purpose of these requirements is to enhance vehicle stability during brake application on roads in all conditions, dry and wet, as well as icy. A copy of Standard No. 121 with amendments is enclosed.; Please write again if I can be of further assistance. Sincerely, James C. Schultz, Chief Counsel

ID: aiam2404

Dear Mr. Gill: This is in reply to your letter of September 23, 1976, asking for a interpretation of the spacing requirements for motorcycle turn signal lamps specified in Table IV of Motor Vehicle Safety Standard No. 108.; Standard No. 108 requires that motorcycle turn signal lamps be locate so that their edges are at least 4 inches from the edge of the headlamps (on the front) and tail or stop lamps (on the rear). You have asked for confirmation 'that the minimum separation distance is measured between the edges of the illuminated lenses of the respective lamps on a line passing through each lamp . . . rather than being measured on a horizontal line between two planes touching the edges of the illuminated lenses'.; This will confirm your interpretation that the minimum separatio distance is to be measured at the point where the edges of the two lamps are closest to each other.; Yours truly, Frank Berndt, Acting Chief Counsel

ID: nht87-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/87

FROM: HANNS-OTFRIED WESTERMANN--HELLA KG HUECK & CO.

TO: DR. BURGETT--NHTSA

TITLE: RE MULTI BULB DEVICES

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO H. WESTERMANN FROM P. J. RICE; (A36; STD. 108)

TEXT:

We intend to equip motor vehicles with signalling devices, which have - opposite to conventional lamps - a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb. The miniature bulbs are about 2 to 3 cp each, as is actually applied t o CHMSL.

This design shows a number of advantages:

1. The failure probability of the signal function of a device is very low, because the burn out of a single bulb does not drop the light-out-put of the lamp below the minimum value required.

2. The average life of the miniature-bulbs is greater than the one of current 32 cp bulbs: about 3 per cent mortality rate after 1500 burning hours.

3. The devices can be built smaller and particularly with less depth.

4. The openings in the vehicle's body work can be avoided in part or totally, because the devices can be surface mounted.

5. The absence of body work openings increases the vehicle's stability and avoids sealing problems.

Summary: "Multi-bulb-devices" increase the traffic safety and lower the system costs over the vehicle's life time.

FMVSS No. 108 opposes this idea, because it is required that lamps with 2, 3 or more lighted sections have to comply with higher intensity requirements than a lamp with only one compartment or bulb. The reason for this requirement is to assure a uniform ly conspicuous surface luminance. These higher intensity requirements because of the larger overall lens area are not applicable to our design with a great number of miniature bulbs.

In spite of the great number of bulbs (10 to 20, depending on function) the total area of the lamp is not larger than the one of current one-compartment-lamps. The luminous Intensity requirement for 3- or more compartment lamps for this lamp size would c ause undesirable high luminances.

For each of the many bulbs the lighted lens area is substantially smaller than the required minimum area (22 inches square) for each compartment of multi-compartment lamps, but the total area of all bulbs is in compliance with the requirement for one-com partment-lamps.

We kindly ask for your comment on the legal aspects of this deviating design with many miniature bulbs and in particular, whether the intensity requirements of single-compartment lamps are applicable. (For LED-lamps it is even discussed, that for their higher conspicuity the intensity requirements could be lowered below those of single-compartment lamps). In our opinion the minimum requirements should not depend on the type of design (number of bulbs or compartments) but on the overall visible lens ar ea.

We want to draw your attention to the changes of ECE Regulations R6 and R7:

"If with a single lamp containing more than one bulb one of this bulbs fails, the lamp with the remaining bulbs shall comply with the minimum value required ...

Any failure of a bulb in such a lamp shall be clearly visible, if the lamp is switched on."

ID: aiam1971

Dear Mr. Bernard: This is in reply to your letter of May 28, 1975, providing furthe information for our determination whether certain 'safety lights' would violate the National Traffic and Motor Vehicle Safety Act of 1966.; There is no Federal prohibition against sale of this accessory in th aftermarket. It would, however, be subject to regulation by the states. For the following reasons, it could not be used as original equipment. Standard No. 108 requires a minimum spacing of 4 inches (edge to edge) between the stop lamps and the rear turn signal lamps and a minimum spacing of 9 inches (centerline to centerline) between the turn signals. The purpose of this spacing is to provide a distinctive indication of the turning direction. A flashing stop lamp located in close proximity to the steady-burning stop lamp required by Standard No. 108 would, in our opinion, impair the effectiveness of the rear turn signal within the meaning of S4.1.3, during a combined braking and turning operation. Such a lamp would also be prohibited by S4.6(b) which, in effect, requires all original equipment stop lamps to be steady burning.; Yours truly, Richard B. Dyson, Assistant Chief Counsel