Interpretation ID: babcock.ztv

Mr. Robert Babcock
Manager, Corporate Affairs
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108

Dear Mr. Babcock:

This is in reply to your letter of January 8, 2003, asking for an opinion whether a multi-component rear reflex reflector configuration would comply with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The rear reflex reflector configuration in your design consists of three separate reflex reflectors. One reflector is installed on the fender and a second reflector is located adjacent to it, on the deck lid. The third reflector is hidden by the deck lid (it is a reflex reflector located on the flange of the outer lamp housing) and it is not visible until the deck lid is raised. No single reflector fulfills the photometric requirements for a rear reflex reflector, but these requirements are met when the reflector on the fender and either of the other two reflectors are measured.

Your design is not a permissible configuration under Standard No. 108. The applicable standard incorporated by reference in Standard No. 108 is SAE J594f, "Reflex Reflectors," January 1977. The text and setup for testing set forth in SAE J594f clearly indicate that the requirements of this standard apply to a single reflex reflector, and may not be met using a combination of separate reflex reflectors. If you wish to proceed with this configuration, we recommend that the reflector located on the fender be redesigned to meet the requirements of SAE J594f. We also note that, for whatever configuration you use, Standard No. 108 requires rear reflex reflectors to be as far apart as practicable.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.5/22/03