Interpretation ID: 16136.ztv

Mr. Richard Rawlins
Triumph Homologation
Triumph Designs, Ltd.
Dodwells Bridge Industrial Estate
Jacknell Road
Hinckley, Leicestershire
LE10 3BS
England

Dear Mr. Rawlins:

This is in reply to your fax of September 24, 1997, to Luke Loy of this agency, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. For future reference, the Office of Chief Counsel is the appropriate office to which you should address requests for interpretations of the Federal motor vehicle safety standards.

You have asked whether rear side reflex reflectors on motorcycles must be mounted parallel to the vehicle's longitudinal centerline, or whether it is permissible to locate them approximately 9 degrees offset from the centerline.

Under Standard No. 108, lighting equipment is photometrically tested in the laboratory but must comply when installed on a motor vehicle. Thus, a reflex reflector should be mounted on the goniometer in the position in which it will be installed on a motor vehicle as well as being mounted in conformance with the specifications of SAE Standard J594f "Reflex Reflectors" January 1977, incorporated by reference in Standard No. 108. If the reflector meets the photometric requirements of SAE J594f when it is approximately 9 degrees offset from a line representing the motorcycle longitudinal centerline, then it would be permissible to mount it in an identical offset fashion on the motorcycle itself.

If you have any questions you may refer them to Taylor Vinson of this Office.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.10/30/97