Interpretation ID: 86-6.5

TYPE: INTERPRETATION-NHTSA

DATE: 12/05/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: no addressee

TITLE: FMVSS INTERPRETATION

TEXT:

This is in reply to your letter of September 12, 1986, to the National Highway Traffic Safety Administration, and your letter to me of november 13, asking for our comments on four new motor vehicle lighting devices.

The first device performs a combination of two functions. It consists of three lamps serving as identification lamps and will meet all requirements of Standard No. 108 for such equipment. The three lamp cluster will also serve a auxiliary stop lamps (mistakenly referred to as a turn lamp in the November letter). The second device is a clearance lamp meeting requirements of Standard No. 108, which would also serve as an auxiliary stop lamp (also mistakenly referred to a a turn lamp in the November letter). The third device is described as a "tracking lamp" ( the diagram shows this to be the rear side marker lamp required by Standard No. 108) meeting all requirements for such; it will also serve as an auxiliary side turn signal indicator. The fourth device will serve as an intermediate side marker lamp, complying with Standard No. 108's requirements, but will also serve as an auxiliary side turn signal lamp. The devices are intended for use on wide trucks and trailers. In your opinion, the auxiliary functions will not "confuse or inhibit" the functioning of lighting equipment required by Standards No. 108.

With respect to the combination of lamp functions or truck and trailers, Standard No. 108, specifically paragraph S4.4, prohibits only the optical combination of clearance lamps with taillamps or identification lamps. These combinations do not exist in any of your four proposed designs. Under paragraph S4.1.3 supplemental lighting devices are permitted as long as they do not impair the effectiveness of lighting equipment required by Standard No. 108. You have concluded that there would be no impairment. Under the facts as presented in your letter, we have no reason to disagree with that conclusion.

We have noted your request that your letters be accorded confidential treatment because of proprietary commercial information, and your attorney's consent on your behalf that our interpretation may be made public provided that all information identifying you as the writer is deleted. We shall follow this procedure.

Sincerely,

Erika Z. Jones Chief Counsel