Interpretation ID: 1985-01.42
TYPE: INTERPRETATION-NHTSA
DATE: 03/01/85
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Mr. T. Chikada Stanley Electric Co. Ltd.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. T. Chikada Manager Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro, Meguro-Ku Tokyo 153, Japan
Dear Mr. Chikada:
This is in reply to your letter of January 18, 1985, to Mr. Vinson of this office asking for three interpretations of Motor Vehicle Safety Standard No. 108 with respect to motorcycle lighting.
Your first question is about the location of rear turn signals. Table IV of Standard No. 108 requires that rear turn signal lamps on motorcycles have a minimum horizontal separation distance "centerline to centerline" of 9 inches. You have asked whether this may be interpreted as filament center to filament center. The answer is no. The phrase means the distance from the geometric center of one lamp to the geometric center of the other.
Your second question concerns the permissibility of an arrangement of lamps on the rear of a motorcycle. There would be a two-compartment combination stop/tail lamp on the vehicle centerline with separate combination lamps below it on either side of the centerline. The distance between filament centers of the separate lamps would be a maximum 16 inches, and there would be the same distance between the filament centers of each separate lamp and the compartment above it belonging to the two-compartment lamp. You have asked whether this is permissible if the minimum design candlepower complies with requirements for three lighted sections in SAE J585e and SAE J586c, and the effective projected luminous lens area of each compartment or lamp is at least 3 1/2 square inches. This arrangement, though unusual, appears to be acceptable. SAE Standard J586c Stop Lamps and SAE J585e Tail Lamp state that if multiple compartment or multiple lamps are used, and the distance between filament centers does not exceed 16 inches for three compartment or lamp arrangements, the combination of the compartments or lamps must be used to meet the photometric requirements for the corresponding number of lighted sections. Your design has four lighted sections, whereas the SAE Tables provide values for only three. In our opinion, your design would be acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.
Your final question concerns a combination stop/taillamp of four sections, two each on either side of the vertical centerline. Though no distance is given for the filament centers, they appear to be closer than 16 inches. You have asked if this design is permissible provided it meets the requirements for three lighted sections, and the effective projected luminous lens area of each compartment is not less than 3 1/2 square inches. The answer is yes, this is acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.
Sincerely,
Original Signed By
Frank Berndt Chief Counsel
January 18, 1985
Att. : Mr. Taylor Vinson Lawyer
Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, SW. Washington, D.C. 20590 U. S. A.
Re: Required Lighting Equipment for Motorcycle
Dear Mr. Vinson,
1) Location of Rear Turn Signal Lamps
1-. By Table III in FMVSS 108, it specifies, is applicable SAE Standard or recommended practice to follow SAE J588e, September 1970. 2-. by 4.2 in the above SAE Standard it reads "The optical axis (filament center) of the front turn signal shall be at least 4 in. from the inside diameter of the retaining ring of the headlamp unit providing the lower beam." 3-. Whereas by Table IV in FMVSS 108, when rear turn signal for motorcycle, it specifies, "having minimum horizontal separation distance (centerline of lamps) of 9 inches."
Our interpretation of the above -3 is between filament center to filament center. Please confirm.
As a matter of information, please refer to 6.1 in SAE J131 83MAR, Motorcycle Turn Signal Lamp - SAE Standard.
2) Location of two (2) Multiple Lamp Arrangement including one (1) Multiple Compartment Lamp and minimum design candlepower requirements of Stop/Tail Lamp (rear combination lamp) .
1-. By Table III in FMVSS 108, it specifies as applicable Standards to follow SAE J585e September 1977 for Tail Lamp and SAE J586c August 1970 for Stop Lamp. Would an arrangement on the next page be allowed to use when minimum design candlepower requirements complies with 3 lighted section in the above SAE Standards and the effective projected luminous Stop lens area of each compartment or lamp meets at least 3 1/2 sq. inches?
"INSERT GRAPHICS"
3) Four (4) or more Multiple Compartment Lamp of Tail/Stop Lamp (rear combination lamp).
1-. Would the following lamp as long as minimum design candlepower requirements complies with 3 lighted section in the SAE Standards in the (2) on the page 1 and each effective projected luminous stop lens area of each compartment or lamp meets at least 3 1/2 sq. inches be allowed to use?
"INSERT GRAPHICS"
We would appreciate it very much having your reply as early as possible.
Sincerely,
Stanley Electric Co., Ltd.
T. Chikada, Manager Automotive Lighting Engineering Control Dept.
KW/es