Interpretation ID: 1982-2.25

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: P. S. Woolley

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 26 1982

Mr. Phillip S. Woolley 10769 63rd Way N. Pinellas Park, FL 33565

Dear Mr. Woolley:

This is in reply to your letter of July 8, 1982, to Mr. Vinson of this office asking what you must do pursuant to Federal regulations as a manufacturer of taillamps for boat trailers.

The Federal motor vehicle safety standard you must consider is Standard No. 108, Lamps, Reflection Devices, and Associated Equipment. (Title 49, Code of Federal Regulations, S571.108) Under its terms, every vehicle taillamp must meet the requirements of SAE Standard J585e Tail lamps (Rear Postion Lamps), September 1977, and the SAE materials referenced in J585e, except that paragraph S4.1.1.12 of Standard No. 108 establishes alternative photometric equipment. The standard does not establish per se a minimum lens area for a taillamp. However, a vehicle manufacturer is required to ensure that when a tail lamp is installed, "the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex," at least 2 square inches in extent, measured at 45 deg. to the longitudinal axis of the vehicle" (paragraph 4, J585e).

As a manufacturer, you are required to certify compliance of each taillamp with all applicable Federal motor vehicle safety standards, which may be by labelling the lamp with the symbol DOT, or by a statement on the lamp or on its shipping container (paragraph S4.7.2, Standard No. 108). You are also required to file an identification statement with the agency (49 CFR Part 566). In the event any taillamp fails to comply with Standard No. 108, or incorporates a safety-related defect, you must notify purchasers and remedy the problem in the manner specified by 49 CFR Part 577, after filing a report with the agency (Part 573).

You may obtain a copy of all Federal requirements by sending a check for $8 to the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 and asking for "Title 49 Code of Federal Regulations - Parts 400 to 999, revised as of October 1, 1981."

For further information on the SAE materials, write "Technical Division, SAE, 400 Commonweath Drive, Warrendale, PA 15096 (or call 412-776-4841). In addition to J585e, you will need copies of J575e Tests for Motor Vehicle Lighting Devices and Components, August 1970; J576d Plastic Materials for Use in Optical Parts Such as Lenses and Reflection of Motor Vehicle Lighting Devices, June 1976; and J578c Color Specification for Electric Signal Lighting Devices, June 1977.

Sincerely,

Frank Berndt Chief Counsel

Phillip S. Woolley 10769 63rd Way N. Pinellas Park, Fl. 33565

July 8, 1982

Mr. Taylor Vinson - F.M.V.S.S. - 108 Legal Counsel National Highway Traffic Safety Assoc. Room 5219 400 7th Street S.W. Washington, DC. 20590

Dear Mr. Vinson:

Our company intends to manufacture tail lights for boat trailers and we need to know in laymans terms exactly what we have to do to comply with the rules and regulations set by the Federal Department of Transportations section 108. Are there any rules regarding square inches of lens surface area?

Thank you very much,

Phillip S. Woolley

P.S. Your name was referred to me by the National Highway Transportation Dept.

PSW/kw