ID: nht91-1.9

DATE: January 3, 1991

FROM: Jim Holperin -- State Representative, 34th Assembly District

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-26-91 from Paul Jackson Rice to Jim Holperin (A37; Std. 108)

TEXT:

I write today on behalf of LeRoy E. Mueller, President of the Wisconsin Trailer Company, Inc. in Phelps, Wisconsin. Mr. Mueller's company recently submitted a bid to the Wisconsin Department of Natural Resources for two tilt-deck trailers based on the enclosed specifications.

As Mr. Mueller is concerned that if he builds the trailers exactly to specifications that they will be in violation of Title 49, Section 571-108 and, by cross reference, in violation of relevant SAE requirements.

Kevin Cavey recommended I direct this correspondence to you and request a determination from the NHTSA regarding whether our DNR's trailer specifications comply with Title 49 and relevant SAE codes. I am also enclosing a letter from Mr. Mueller indicating his primary concern lies with what appears from the specifications to be a permanent, stationary ramp which Mr. Mueller believes might obscure a clear view of the trailer's tail lights from a 45 degree angle as required by Title 49 and SAE codes.

I would appreciate it if you could take time to review the enclosed material and determine whether Mr. Mueller's concerns regarding an obstructed view of the tail light are legitimate or not. Thank you for giving this request your consideration and, of course, if there is additional information you need please do not hesitate to contact me by letter or phone.

Attached to a map of the 34th Assembly District (Text omitted)

Attachment Specification 8 SPECIFICATION

TYPE: (2) Two 26,000 lb. minimum payload capacity "over the wheel" tilting platform trailer.

DELIVERY: The successful bidder shall deliver all units ordered, after final inspection and approval by DNR personnel, to DNR, Neil H. LeMay Forestry Center, 518 West Somo Ave., Tomahawk, WI 54487, and to arrive during regular working hours - Monday thru Friday, 7:45 a.m. to 11:45 a.m. and 12:30 p.m. to 4:30 p.m. Advance notice of at least one day shall be given. The successful bidder shall arrange for and pay transportation costs for the delivery of all units ordered.

USE: Trailer will be used to transport medium sized crawler tractors with fire plows, heavy duty wheel tractors, and farm-type machinery, both on and off the road, maximum highway speed will be 55 MPH.

A. CAPACITY: 26,000 lb. minimum payload capacity. When unloaded, there shall be sufficient tongue weight to enable the unit to be towed without fish-tailing.

OUTLINE DRAWING - T-D169-401 Issue 02

B. PLATFORM: Length - 20 feet Width - 94" minimum - 96" maximum Height - 38" maximum fully loaded

FRAME: Steel shall be designed with ample safety factor and electrically welded where steel meets steel. All crossmembers are to be in line, fully welded on top, sides, and bottom, both on the inside and outside of the main frame.

DECK: Full 2 inch thick treated apitong wood deck. The entire rear 7 feet of the trailer to be ribbed traction bed with 3.75" x 2" x 3" angle steel ribs replacing the wood deck planking. Ribs to be spaced 7" on center with the 3" leg facing the front of the trailer. All wheel well openings shall be covered. Area around wheel wells shall be reinforced to support deck.

ANGLE IRON LOADING GUIDES: Locate three removable angle iron guides on top of deck per outline drawing.

Stake pockets, footholds, expanded metal walkway, tie-down slots per outline drawing.

LOADING RAMPS: 0.50" thick steel formed loading ramps per outline drawing.

PLATFORM LOCK: Shall be heavy duty screw type, self adjusting for wear, and shall hold the platform tight and rattle free in the closed position, The end of the screw shall be wedge shaped for ease of engagement.

OPERATION: Deck to tilt open or closed with 150 lb. weight, allowing loading or unloading of equipment. Loading angle shall not exceed 15 degree incline. Zerk type grease fittings shall be on all platform tilt pivot points.

SPECIFICATION

CUSHIONING DEVICE: One (1) 4" hydraulic cylinder with 1.25" diameter rod, or two (2) 2.5" hydraulic cylinders with 1" diameter rod (all minimum dimensions) designed to cushion the opening and closing the platform. When cylinders are completely open, the bed of trailer shall be capable of tilting 4" minimum below ground level in the tiltbed position.

C. SUSPENSION: Single point spring suspension - Neway USR 444, or equal - able to maintain equal ground pressure while traveling over uneven terrain.

AXLE LOCATION: Distance from center of axles to front of trailer bed to be approximately 10 feet.

TIRES: Nine (9) 7.5 x 15 L.R. "F" (12PR) low platform trailer tube type tires and rims capable of meeting load and speed requirements of this specification as noted in item A. One (1) tire to be mounted on spare rim. Valve extensions required on inside tires.

WHEEL: Budd disc wheels. Stemco oil wheel seals shall be furnished on all axles.

AXLES: Full width through type axles with one (1) hubometer.

D. BRAKES: Full air complete with all lines, breakaway control valve, and air reservoir tank with 1,000 cubic inch minimum capacity. Air brake hoses to extend a minimum of 24" ahead of the pintle eye and shall be complete with couplings. Air lines shall not be interchangeable. Left gladhand shall be the emergency air line Velvac #55B-13. Right hand gladhand shall be the service air line Velvac #55B-14. Brake system shall meet SAE and DOT requirements. All wheel brakes to be 12.25" x 7.5" minimum. Gladhand holders are required for brake lines when they are not in use, and are to be mounted near tongue. Include piggy back parking with mechanical release and mechanical release tool.

E. ELECTRICAL SYSTEM: Shall be per writing diagram T-AO86-701 furnished as a part of this specification.

WIRING: Shall meet all SAE, ICC, and DOT requirements. All wires shall be in loom, heavy jacket, or conduit and mounted in a protected position. Where wires pass through steel, they shall be protected with rubber grommets. Two (2) feet of conductor wire, ahead of pintle, shall be installed in the female plug for connection to the towing vehicle. No aluminum rivets for grounds are allowed.

LIGHTS: Lights shall meet SAE, ICC, and DOT requirements. Lights shall be in protected recesses or with protective base around lights. All lights shall be of the plug-in type.

SIX POLE PLUG: Vel Vac #59P-6 (6 way male plug) with replaceable interior, or equal.

Attached to drawings and photos of Lid Trailer (Text and graphics omitted)

ID: 86-6.7

TYPE: INTERPRETATION-NHTSA

DATE: 12/08/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Roger Hagie -- Government Relations Manager, Kawasacki Motors Corp. USA

TITLE: FMVSS INTERPRETATION

ATTACHMT: 10/20/83 letter from F. Berndt to BMW of North America, Inc.

TEXT:

Mr. Roger Hagie Government Relations Manager Kawasaki Motors Corp. USA P.O. Box 25252 Santa Ana, CA 92799-5252

Dear Mr. Hagie:

This is in response to your letter of April 26, 1985, asking for an interpretation of Motor Vehicle Safety Standard No. 108. I regret the delay in responding to your letter.

Specifically, you have called our attention to a proposed motorcycle accessory, consisting in part of a "nylon mesh which is stretched in front of the headlamp lens" and intended to protect the "headlamp from damage by stones or other road debris." You have asked whether this accessory would be permissible under paragraph 54.1.3 of Standard No. 108 which in effect allows optional equipment that does not impair the effectiveness of the lighting equipment that the standard does require. You have advised us that "the nylon mesh does cause some reduction in the photometric output of the lamp" but that testing of the specific headlamp that the mask is designed to fit "has determined that with the mesh in place, light output is still more than 1208 of the minimums specified by SAE J584.. . " You have quoted a 1983 letter from the former Chief Counsel giving two examples of impairment, one a plastic cover causing a dislocation of beam pattern, or a cover that is subject to accelerated hazing or cracking, but you have stated that it is unclear whether any degree of impairment is unacceptable, or only an impairment that causes light output to fall beneath the minimum photometrics prescribed by Standard No. 108.

Because Federal motor vehicle safety standards are minimum performance standards, the fact that the mesh causes some reduction in photometric output does not mean that it "impairs" the effectiveness of the headlamp unless it reduces light output below the minimum levels imposed by the standard. You have stated that with the mesh installed light output is still more than 120% of the minimum required. If Kawasaki is satisfied that this output will be met with any original equipment headlamp, then it may certify compliance with Standard No.

108 of any motorcycle on which the mesh is an original equipment accessory.

The question of the permissibility of the mesh as an after market accessory is not easily answered. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibits actions by manufacturers, distributors, dealers, and motor vehicle repair businesses that "render operative in whole or in part" equipment which has been installed to comply with a Federal vehicle safety requirement. We would view dealer-installation of the mesh as rendering a headlamp partially inoperative if it resulted in a diminution of headlamp light output below the standard's minimum level. The prohibition does not apply to owner modifications. Whether an owner modification is legal is answerable under the laws of the States where a vehicle is registered and operated.

A further observation is that although an original equipment headlamp-mesh combination may meet or exceed the minimum photometrics, it is possible that a replacement headlamp would fall beneath the threshold of photometric compliance with the mesh in place. We suggest that you consider these safety issues before proceeding to offer the accessory.

Sincerely,

Erika Z. Jones Chief Counsel

April 26, 1985

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

RE: Request for Interpretation, FMVSS 108

Dear Sir:

Kawasaki Motors Corp., U.S.A. requests an interpretation of the acceptability of a proposed motorcycle accessory, a device to cover and protect the leading surface of a motorcycle fairing and headlamp from damage by stones or other road debris.

More specifically, the product consists of a vinyl or leather "mask" which fits snugly to the front of the fairing and incorporates a nylon mesh which is stretched in front of the headlamp lens.

Our question relates to the issue of whether this mesh covering over the headlamp lens is permissible according to FMVSS 108. Your attention is directed to the letter of October 20, 1983 from then Chief Counsel Frank Berndt to Karl-Heinz Ziwica of BMW North America (file ref. NOA-30), copy attached.

In this letter, Mr. Berndt indicates that NHTSA has "concluded that headlamp covers for motorcycles are not per se prohibited by Standard 108." Mr. Berndt continues to indicate " if they impair the effectiveness of the headlamp." He goes on to describe two examples of impaired effectiveness that the agency would presumably consider contrary to the intent of FMVSS 108: an extreme installation angle of the cover or deterioration of the cover itself.

What remains unclear from Mr. Berndt's letter is whether any degree of impairment of the light output is to be considered unacceptable, or whether the unacceptable level might be reached if the impairment caused light output to drop below the photometric standards applicable to the lamp.

In the case of the mask under consideration by Kawasaki, the nylon mesh does cause some reduction in the photometric output of the lamp. However, testing of the specific headlamp that this mask is designed to fit has determined that with the mesh in place, light output is still more than 120% of the minimums specified by SAEJ584, the applicable standard. Thus, while some "impairment" is acknowledged, performance with the mask in place still exceeds the requirements of FMVSS 108.

In conclusion, Kawasaki seeks NHTSA's opinion whether a mesh headlamp cover which is not subject to hazing, cracking or discoloration, and which does not cause light output to drop below the minimum levels specified by FMVSS 108 would be considered in Compliance with FMVSS 108 if offered for sale on a specific Kawasaki motorcycle.

Thank you for your attention to this matter.

Sincerely,

KAWASAKI MOTORS CORP., U.S.A.

Roger Hagie Government Relations Manager

See 10/20/83 letter from F. Berndt to BMW of North America, Inc.

ID: nht95-2.86

TYPE: INTERPRETATION-NHTSA

DATE: May 18, 1995

FROM: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc

TO: Walter Myers -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO JIM BURGESS (A43; REDBOOK 2; STD. 206)

TEXT: Dear Mr. Meyers:

Per our conversation earlier today, I am writing to learn your interpretation of 49CFR, 571.206, S4, as it pertains to our vehicles.

As we discussed, for eight (8) years, Independent Mobility Systems, Inc., has been converting Chrysler minivans, and recently Ford minivans, into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp in the passenger side rear sliding door area. We have crash tested these converted vehicles at OTRC in Ohio for FMVSS 571.208 Frontal Impact, and for FMVSS 571.301 Rear Impact and Side Impact, to gain certification.

In regard to 49CFR, 571.206, S4, our interpretation is that side doors on motor vehicles which are equipped with wheelchair lifts, and linked to an alarm system consisting of either a flashing visible signal located in the driver's compartment or an alar m audible to the driver which is activated when the door is open, need not conform to this standard, pertains to our converted vehicles. We believe the wheelchair ramp we employ serves the same function as a wheelchair lift, in that it provides those per sons in wheelchairs or access to the vehicle, and thus we do not have to conform to this standard.

Because we have had inquiries from customers on this issue, your written interpretation to our inquiry will be appreciated.

ENCLOSURE

June 16, 1995

Dear Mr. Meyers:

As per our telephone conversation this morning, I am sending the enclosed brochures on our current offerings. As I stated, we are working on converting the new 1996 Chrysler NS minivans. We are scheduled for crash testing this vehicle the latter part o f July and offer it for sale in mid-August.

If you have any further questions before ruling on our request of May 18, 1995, regarding interpretation of 49 CFR, 571.206, S4, please call me.

Sincerely,

INDEPENDENT MOBILITY SYSTEMS, INC.

Jim Burgess Engineer

Enclosure: RAMPVAN BROCHURE/PHOTOS OMITTED

ID: aiam1084

Dear Mr. Feldmann: Thank you for your letter of March 23, 1973, concerning Federal Moto Vehicle Safety Standard No. 215, Exterior Protection.; Your first concern is the fact that bumpers which comply with Standar No. 215 still permit damage to occur to the vehicle during low- speed impacts. This situation occurs because Standard No. 215, which initially became effective on September 1, 1972, was developed in accordance with the National Traffic and Motor Vehicle Safety Act of 1966. This Act provided the authority to develop standards to improve vehicle safety during collisions, not solely to reduce property damage. The authority to develop bumper standards primarily to reduce property damage, the Motor Vehicle Information and Cost Savings Act, became law on October 20, 1972. As the result of this new Act, we are in the process of developing standards which limit automobile damage in low-speed bumper impacts.; Secondly, you cite the mismatch problems that continue to exist amon passenger car bumpers. Commencing with 1974 model cars, Standard No. 215 specifies requirements directed at correcting the mismatch problems that cause damage to safety-related components during low-speed, car-to-car collisions. It establishes a uniform interfacing surface among all cars that reduces the likelihood of override, underride, and interlock, all of which are quite prevalent with existing bumper designs.; Thirdly, you express concern over the numerous collisions involvin damage to corners of vehicles. Standard No. 215 also specifies requirements for 1974 model cars that will provide improved corner protection. A copy of the standard is enclosed for your use.; Lastly, you indicate the availability of inexpensive energy absorbin devices that could be used to manage the low-speed crash forces. We are aware of these and other devices of this type, however, as you will note, Standard No. 215 specifies minimum performance only without specifying the equipment or configuration to be used. We feel that this approach encourages competitive innovation and promotes technological progress to achieve the desired performance at minimum cost to the consumer.; We appreciate receiving your comments and your interest in improvin motor vehicle safety.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam2363

Dear Mr. Mathieson: this responds to Thomas Built Buses' June 4, 1976, question whether th requirements in S5.1.3 and S5.1.4 of Standard No. 222, *School Bus Seating and Crash Protection*, to 'Apply additional force...through the...loading bar until (a specified number) of inch-pounds of energy has been absorbed in deflecting the seat back...' can be satisfied in part by the energy that is returned to the load bar as it is withdrawn from the seat back. You also ask if there are minimum or maximum time limits on withdrawal of the loading bar from the seat surface.; The requirement for the absorption of a minimum amount of energy i deflecting the seat back in the forward and rearward directions is calculated to provide adequate measurement of the energy involved in the impact between the bus occupants and the seating in a percentage of school bus crashes. The agency calculated the amount of energy to be consumed by the seat back that would result in adequate protection. The specification requires the seat to 'absorb' (i.e., receive without recoil) a specific amount of energy. This value is represented by the amount of energy that is not returned to the loading bar as it is withdrawn. Described graphically, the area that represents returned energy under the seat back force/deflection curve must be subtracted from the entire area that lies under the curve in order to calculate the energy 'absorbed' by the seat back.; With regard to your second question, no time limits have bee established for withdrawal of the loading bar. The agency intends to utilize a withdrawal time that is not more than five minutes so that creep will not be a significant factor in determining energy absorption. Because the time is not specified, the manufacturer is free to use any reasonable time that does not significantly affect the elastic and plastic components of the seat back loading.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam5613

Dear Mr. Moore: This responds to your letter of July 31, 1995, wit respect to lens area requirements of amber turn signal lenses. You believe that 'by reducing the minimal area of the Amber Turn Signal light lens from 12 square inches to approximately 8 square inches or 6 square inches the U.S. would have more practical rules for U.S. Exports at no expense to Safety. You ask that, 'If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a `Petition for Change of FMVSS; "108 Request''. Standard No. 108 contains two relevant regulations, on applicable to vehicles whose overall width is less than 80 inches, and one to those whose overall width is 80 inches or more. Under paragraph S5.1.1.26(a), the functional lighted lens area of a single turn signal lamp of either red or amber on a vehicle whose overall width is less than 80 inches shall be not less than 50 square centimeters. This is approximately 8 square inches. Therefore, no rulemaking is required to implement your recommendation. The standard that applies to turn signal lamps on vehicles whose overall width is 80 inches or more is SAE Standard J1395 APR85, incorporated by reference in Standard No. 108. Under its paragraph 5.3.2, the functional lighted lens area of a single turn signal lamp shall be at least 75 square centimeters, or approximately 12 square inches. Therefore, rulemaking is required to implement your recommendation. We are transmitting your letter to our Office of Safety Performance Standards for consideration as a petition for rulemaking to change the minimum lens area requirement for turn signal lamps on large vehicles from 75 to 50 square centimeters. On September 4, 1995, I determined that your letter met our procedural requirements for a petition. Accordingly, the Office of Safety Performance Standards will inform you not later than January 1, 1996, whether your petition has been granted. If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel";

ID: aiam0233

Dear Mr. Haaversen: Thank you for your letter of March 9, 1970, to the National Highwa Safety Bureau, concerning our Federal motor vehicle tire standards.; The only tire standard promulgated to date is Federal Motor Vehicl Safety Standard No. 109, 'New Pneumatic Tires-Passenger Cars' which was effective January 1, 1968. This standard specifies minimum performance for size, strength, endurance, high speed laboratory testing and labeling. For your information, I have enclosed a copy of Standard No. 109 and No. 110 with amendments.; The replies to your specific questions are as follows: >>>1. *Question:* New American made tires have DOT load ranges, loa capacity and inflation pressures molded into the sidewall. Is this required (that they be *permanently* marked), or is it sufficient to affix a temporary marking (such as a sticker) with this same information?; *Response:* Section S4.3 states that this information shall b permanently molded into or onto all new passenger car tires manufactured after August 1, 1968. If the tire was manufactured between January 1, 1968 and July 31, 1968 the labeling requirements may be met by use of a label or tag.; 2. *Question:* How is load capacity information arrived at? Is it b manufacturer certification, government conducted tests, or some other method?; *Response:* The load/inflation schedule is calculated by use o empirical formulas and coordinated through the various Tire and Rim Associations as well as the Society of Automotive Engineers.; 3. *Question:* Is it necessary that these tires be subject to safet tests? These particular tires are already imported by another organization and may already have passed the necessary tests, if any.; *Response:* The application of the 'DOT' recital to a tire, is the tir manufacturers self certification that his tire conforms to all the minimum performance standards of Federal Motor Vehicle Safety Standard No. 109.<<<; I have also enclosed for your review and information the followin data:; >>>1. U.S. Customs Regulations for Importation of Motor Vehicles an Items of Motor Vehicle Equipment.; 2. Automobiles Imported Into the United States.<<< Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs;

ID: aiam4158

Dear Mr. Williams: This is in reply to your letter asking about regulations applicable t the 'new lights that are now being seen on the trunk lids, and the rear windows of new automobiles'.; The specific legal name for this light is 'center high-mounted sto lamp.' It was optional for use as original equipment on passenger cars manufactured between August 1, 1984 and September 1, 1985. It has been mandatory original equipment since them. The Federal regulation that requires it is Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment* issued by the National Highway Traffic Safety Administration of the Department of Transportation. This standard specifies color, minimum illuminated lens area, mode of operation, etc. for original equipment, and for equipment intended to replace that original equipment. The standard does not cover center high-mounted stop lamps intended for use on cars that never had them, and a manufacturer of such aftermarket motor vehicle equipment is subject only to State laws on their design, installation, and use. We encourage aftermarket manufacturers to follow the Federal standard so that the full potential of the lamp may be realized. This means that the lamp should be steady- burning rather than pulsating, and that the lens not have logos, trademarks, or other markings on it to interrupt the transmission of light from the lamp. The standard does not specify the shape of the lamp but virtually all to date have been rectangular (photos of the 1984 Cadillac Allante show a circular one), and some have exceeded the minimum requirement of a lens area of at least 4 1/2 square inches.; Noting your interest as a prospective manufacturer of these devices, enclose a copy of Standard No. 108. Sections 4.1.1.41 (page 218), Section 4.3.1.8 (page 227) and Table III (page 256) provide the relevant requirements for center high-mounted stoplamps. Should you proceed to manufacture aftermarket lamps, you would be subject to the agency's notification and remedy procedures should a safety related defect occur in them. Otherwise, you would appear to be subject only to State laws.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam1034

Dear Mr. Bauer: This is in reply to your letter of January 25, 1973, to Gordo Lindquist, Regional Administrator, NHTSA, asking whether Federal standards require the installation of seat belts on certain vehicles you manufacture. According to brochures you have submitted, these vehicles are your RH 25 3-cu. yd. heavy duty hydraulic shovel, R-150-1 15-ton hydraulic crane, W-350 35-ton hydraulic swinger crane, and T-150 15-ton fully hydraulic truck crane.; With reference to the first three vehicles, the RH 25, R-150-1 an W-350, the NHTSA does not consider these vehicles to be manufactured primarily for use on the public roads. Therefore, they are not 'motor vehicles' subject to regulation under the National Traffic and Motor Vehicle Safety Act of 1966. We view them as construction equipment whose use of the public roads is incidental to their primary work-performing purpose.; THe NHTSA believes, however, based on the information you hav submitted, that the T-150 hydraulic truck crane is a motor vehicle under the Safety Act, and a 'truck' under the motor vehicle safety standards. We base this determination on the vehicle's speed capability, that its manufacturer classifies it as a 'truck crane', and that its overall appearance appears to be that of a vehicle designed to be used on the highway. As a truck, the vehicle is required to be equipped with seat belts as specified in Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208, copy enclosed). It is required also to conform to safety requirements specified in other safety standards and regulations. Copies of the standards can be obtained as described in the enclosed, 'Where to obtain Motor Vehicle Safety Standards and Regulations'.; Our decision as to whether this vehicle is a motor vehicle is base only on that information which you have provided us. Other relevant factors which can be taken into consideration are set forth in the enclosed interpretation regarding mini- bikes. If you have further information which you believe we should also consider we will be glad to review it.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: aiam2410

Dear Mr. Heath: This is a reply to your letter of September 16, 1976, referencing a opinion letter to you dated October 21, 1969, and asking whether it conflicts with an opinion letter to Ford Motor Company dated 'December 5, 1975'. (The true date of the letter is July 7, 1975, we do not know why your copy is dated otherwise).; The 1969 letter informed you that 'if one compartment or lamp [in multicompartment lamp] meets the photometric requirements [of Standard No. 108] the additional compartments or lamps are considered as additional lamps and are, therefore not regulated by . . . Standard No. 108 except by S3.1.2.'. The letter also stated that 'lamps on a vehicle and not required by this standard are generally subject to regulation by the States.' Our 1975 letter to Ford, on the other hand advised the company in effect that the performance of the entire multicompartment assembly was covered by Standard No. 108, and that section 25950(b), of the California Vehicle Code was preempted by it. You have asked whether our letter to Ford conflicts with our earlier letter to you.; There is no present conflict. In an amendment to Standard No. 10 effective January 1, 1973, (copy enclosed) the agency adopted paragraph S4.1.1.12 and figure 1 which established minimum photometric requirements that must be met by multicompartment tail, stop, and turn signal lamps. The act of establishing requirements for the additional compartments in a multicompartment lamp thus voided the 1969 letter to you and the interpretation to Ford is the correct one.; The Monarch taillamp, therefore, must meet the requirements of Table of standard No. 108 and is not a lamp that is 'in addition to the minimum required number' as that term is used in California Vehicle Code section 25950(b), which appears to have been amended in an effort to include it.; We appreciate your suggestion on an amendment to Standard No. 108 o lens color.; Sincerely,Frank A. Berndt, Acting Chief Counsel