Interpretation ID: nht76-2.39

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 29, 1976, asking whether the "47 Series Tite-Lite," in our opinion, has an "'optically combined' clearance lamp function." The lamp in question is represented as having "two lights [that] provide 15 functions" and you have advised us that "there are no partitions inside the multi-function lens of this lamp."

Paragraph S4.4.1 of Motor Vehicle Safety Standard No. 108 prohibits the optical combination of clearance lamps with tail lamps and identification lamps. This means that a single bulb in the 47 Series Tite-Lite may not provide both tail lamp and clearance lamp functions. It also means that the light emitted by one bulb must not be perceived as performing the function of the other in addition to its design function. You have neither identified the function performed by both bulbs nor provided us with their candle-power output and we are unable to determine whether the lamp complies with Standard No. 108.

SINCERELY,

Trailer manufacturers association

October 29, 1976

Frank A. Berndt U.S. Department of Transportation

Mr. Weber has sent me a copy of your letter to him of October 7, 1976 (reference N40-30).

With respect to paragraphs one and two of your letter, we wish to know if DOT considers the 47 Series Tite-Lite as described inside and on the cover of the enclosed brochure as having an "optically combined" clearance light function, and with respect to this question only, if the lamp is considered to comply with FMVSS No. 108. There are no partitions inside the multi-functions lens of this lamp.

Director of Engineering DONALD I. REED

TITE-LTE

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At last, a Submergible Light System for Boat Trailers . . .