Mr. Nick Tysoe
Development Engineer
Britax Vega Ltd.
Kingswood Road
Hampton Lovett Ind. Est.

FAX 9-011-44-1905-796046

Dear Mr. Tysoe:

This is in reply to your fax of October 30, 1997, to Richard Van Iderstine of this agency. As the Office of Chief Counsel provides the written interpretations of the agency's regulations, please send future requests for interpretations directly to us.

You discuss the design of the rear of a vehicle which has one taillamp installed on the fender and another taillamp adjacent to it on the rear decklid. A distance of four inches separates the two lamps. Each of the lamps conforms to SAE J585 as a single lamp. You regard the fender-mounted lamp as the lamp required by Federal Motor Vehicle Safety Standard No. 108, and the lamp mounted on the decklid as an additional lamp that does not impair the effectiveness of the required taillamp. But if the two lamps are regarded as a two-compartment lamp, "their combined photometric performance will exceed by a small amount the 20cd maximum for such lamps."

You ask whether your interpretation is valid, or whether such an installation would be regarded as a multi-compartment lamp.

We are pleased to confirm your interpretation. A multiple compartment lamp is a lamp that shares a common housing and lens. Your design encompasses lamps with separate housings and lenses, and is not a multiple compartment lamp.

John Womack
Acting Chief Counsel