United States Department of TransportationInterpretation ID: aiam3960
Executive Vice President and General Manager
Mazda (North America)
Inc.
24402 Sinacola Court
Farmington Hills
MI 48018;
Dear Mr. Moriyoshi: This is in reply to your letter of June 3, 1985, asking for a interpretation of Motor Vehicle Safety Standard No. 108 regarding requirements for the center high- mounted stop lamp.; You reference an agency letter of July 30, 1980, to Volkswagen o America in which the Chief Counsel concluded that placement of the stop lamps and taillamps on the deck lid could be viewed as a defect in performance requiring notification and remedy. You have asked, in essence, how this relates to Standard No. 108's present allowance of a center high- mounted stop lamp mounted on a vehicle's decklid, hatch, or tailgate.; The assumption underlying the agency's 1980 letter was that a defec could exist if all a vehicle's stop lamps and taillamps were mounted on the decklid, where their signals could be unobserved or obscured if the lid were in any position other than closed. The center high-mount stop lamp, on the other hand, while an item of required equipment, is nevertheless a supplementary stop lamp. Even if the deck, hatch, or tailgate upon which it is mounted should be open, following drivers may still observe the signals of the primary stop lamps remaining on the body.; You have asked that we also discuss the implications of a stop lamp an taillamp constructed so that a portion is fixed to the body of the vehicle adjacent to the decklid opening and the remaining portion is mounted on the outboard area of the decklid.; Compliance of a vehicle is determined with respect to its norma driving position, that is to say, with the tailgate, hatch, or decklid closed. However, in order to obviate any possibility of the existence of a safety-related defect, we recommend that the portion of the lamp that is mounted on the body itself comply with the minimum requirements of Standard No. 108 for a single compartment stop lamp or taillamp.; I hope that this answers your questions. Sincerely, Jeffrey R. Miller, Chief Counsel