Interpretation ID: aiam3634
Vice President (Technical)
Lucas Industries Inc.
5500 New King Street
Troy
MI 48098;
Dear Mr. Burgess: This is in reply to your letter of November 1, 1982, regarding a interpretation of the 'lens area requirements of FMVSS No. 108' as applied to the high contrast lamp whose design you enclosed.; We understand that your design applies to rear lamps. The measuremen for the illuminated area of a rear lamp as specified in SAE J585e, 'Tail Lamps (Rear Position Lamps),' for example, is stated in part as follows:; >>>...'To be considered visible, the lamp must provide an unobstructe projected illuminated area of outer lens surface....'<<<; This applies to the installation requirements, i.e., the device as use on a vehicle. It is not part of the laboratory test procedure.; Further, with regard to photometric requirements of a lamp, n measurement for the illuminated area of a rear lamp is specified in SAE test procedures.; In summary, Standard No. 108 does not prohibit Lucas from manufacturin the lamp in question, but the vehicle manufacturer must be careful to insure that the lamp, when installed, conforms to the standard's requirements for visibility of lens area.; Sincerely, Frank Berndt, Chief Counsel