Tadashi Suzuki, Manager
Legal & Homologation Section
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153, Japan
Dear Mr. Suzuki:
This is in reply to your letter of August 29, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to two possible arrangements of a motorcycle tail and stop lamp, which has more than three lighted sections.
Attachment 1 to your letter depicts the two rear lamp configurations. Attachments 2 and 3 are copies of correspondence in 1985 between Stanley and this Office asking similar questions about a combination rear motorcycle lamp with more than three lighted sections.
Since Chief Counsel Berndt's letter to Stanley, dated March 1, 1985, SAE Standard J586 FEB84 has replaced SAE Standard J586c, August 1970, as Standard No. 108's specifications for stop lamps for motorcycles. However, there is no substantive change between the two standards that affect the 1985 interpretation. SAE Standard J585e, September 1977, remains the Federal specification for motorcycle taillamps. As before, both standards prescribe requirements for lamps with three lighted sections but are silent as to requirements for lighted sections greater than three.
We have reviewed the paragraphs 3.1 and 4 of SAE Standard J585e, paragraphs 184.108.40.206 and 5.4.1 of SAE Standard J586, and S220.127.116.11 and S18.104.22.168(b) of Standard No. 108. These are the appropriate references cited in your letter that apply to this interpretations. In 1985, we informed you that Stanley's design for a lamp with four lighted sections "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." We affirm that that 1985 interpretation remains our interpretation in 1997.
Acting Chief Counsel