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Interpretation ID: 2622y

Herr Hanno Westermann
Hella KG Hueck & Co
Postfach 28 40
4780 Lippstadt
W. Germany

Dear Herr Westermann:

This is in reply to your letter to Dr. Burgett of this agency with respect to "multi bulb devices", specifically "how the requirements for one-, two-, or three compartment lamps (lighted sections) as it is documented in FMVSS No. 108, Figure lb have to be interpreted. . . ." You have asked this question because "Hella would like to equip motor vehicles with signalling devices which have --opposite to conventional lamps--a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb." Your question assumes that Standard No. l08 is to be interpreted in a manner that equates the number of lighted sections with the number of bulbs providing the light. Finally, you have stated that the total area of the lamp is not larger than current one-compartment lamps.

We regret the delay in responding to your letter, but we have recently completed rulemaking, begun in September l988, which is relevant to your question. On May 15, l990, an amendment to Standard No. l08 was published, effective December 1, l990, the effect of which is to restrict Figure 1b to replacement equipment. I enclose a copy of the amendment for your information.

Your question relates to "signalling devices" for new motor vehicles, and Figure 1b shows that, specifically, you refer to turn signal lamps. Beginning December l, l990, Standard No. 108 will specify two different standards for turn signal lamps. If the lamp is intended for use on multipurpose passenger vehicles, trucks, buses, and trailers whose overall width is 80 inches or more, it must be designed to conform to SAE Standard J1395 APR85 Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. SAE J1395 also provides that these lamps may be used on vehicles less than this width, except for passenger cars. If a motor vehicle is not equipped with a turn signal lamp designed to conform to SAE J1395, it must be equipped with a turn signal lamp designed to conform to SAE Standard J588 NOV84 Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width. In the May l990 amendments, section S3 of Standard No. 108 was amended to add a definition for "Multiple Compartment Lamp". Such a lamp is "a device which gives its indication by two or more separately lighted areas which are joined by one or more common parts, such as a housing or lens." The multiple bulb device that you described appears to meet this definition.

SAE J1395 establishes luminous intensity minima and maxima photometric requirements without reference to either compartments or lighted sections, and all that is required is for the lamp to comply at the individual test points specified. New section S5.1.1.31 clarifies that measurements of a multiple compartment turn signal lamp on vehicles to which SAE J1395 applies are to made for the entire lamp and not for the individual compartments.

However, SAE J588 NOV84 continues to specify different minimum photometric requirements for one, two, and three "lighted sections". Because the SAE does not prescribe photometric requirements for more than three lighted sections, we have concluded that any device that contains more than three lighted sections need only comply with the requirements prescribed for three lighted sections.

I hope that this is responsive to your request.


Paul Jackson Rice Chief Counsel ref:l08 d:8/22/90