ITT Automotive Europe GmbH
Dear Herr Binder:
This responds to your FAX of July 19, 1994, requesting a reinterpretation of our letter to you of June 21, 1994. You had intended to ask us about taillamps rather than the turn signal lamps which were the subject of our letter.
Your latest letter shows a rear motor vehicle lighting array of four lamps, two on the body and two on the tailgate. The lamps on the body contain turn signals, stop lamps, and taillamps. The lamps mounted on the tailgate contain backup lamps, rear fog lamps, and taillamps. Your letter asks for confirmation of your interpretation that:
"This lighting system is a multiple lamp arrangement, therefore the combination of taillamp 1 and taillamp 2 has to be used to meet the photometric requirements for 2 lighted sections (SAE J585e, 3.1 and Table 1)."
This is correct. Paragraph 3.1 of SAE J585e states that "multiple lamps may be used to meet the photometric requirements of a tail lamp." Note 3 of Table 1 states that "separately lighted sections . . . may be separate lamps", and that the photometric values are to apply when all sections that provide the tail signal are considered as a unit.
"Visibility will be judged with tailgate closed."
As we advised you in our earlier letter, this is also correct. "Only taillamp 2 mounted on the tailgate will meet the requirements for an unobstructed projected illuminated area of 12.5 cm2 measured at 45 deg. inboard. This is in accordance with SAE J 585e; Par. 4."
Taillamp 1 and taillamp 2 together comprise the taillamp system. Thus it is not required that taillamp 1 meet the inboard visibility requirements when they are met by taillamp 2.
You have also asked some general questions:
"Are there regulations which lamps has to be mounted on the body and which lamps are allowed on the tailgate?"
No. Table IV's requirement for the location of rear stop, tail, and turn signal lamps is that they be "as far apart as practicable." However, Standard No. 108 does not specify which lamps must be mounted on the body and which are permissible on the tailgate. We encourage manufacturers to mount signal lamps on the body, such as is shown in your drawing.
"Is there a regulation to take an approval test in an authorized test laboratory (e.g. ETL)?"
No. NHTSA has no authority to require a manufacturer to take approval tests or to designate test laboratories of which it approves.
"Which US-Authority has to be informed about this test?"
A manufacturer is not required to inform NHTSA or any other governmental agency about its tests. However, NHTSA has the authority to ask a manufacturer to provide it with copies of test results, and generally does so if it finds failures to meet Standard No. 108 in its own tests.
"How long is this test valid?" "After which period has this test to be repeated?"
Under our laws, a lamp manufacturer is required to certify compliance of replacement equipment with Standard No. 108, and it is the manufacturer's determination when it should retest a lamp to verify that its certification of compliance remains correct. In our experience, manufacturers will retest when there are design changes to its products. Manufacturers also
engage in surveillance testing of products after they have entered production to ensure that design tolerances continue to be met and that the lamp remains in compliance with the specifications of Standard No. 108.
John Womack Acting Chief Counsel