Interpretation ID: nht89-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/24/89

FROM: SADATO KADOYA -- MAZDA RESEARCH AND DEVELOPMENT

TO: STEPHEN WOOD -- ACTING CHIEF COUNSEL OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: REQUEST FOR INTERPRETATION - FMVSS 108: LAMPS, REFLECTIVE DEVICE, AND ASSOCIATED EQUIPMENT

ATTACHMT: LETTER DATED 10/06/89 FROM STEPHEN P. WOOD OF NHTSA TO SADATO KADOYA OF MAZDA, REDBOOK A34, STANDARD 108

TEXT: Dear Mr. Wood:

Mazda would like to ask for your advice and interpretation as to what is the correct interpretation on the location requirement of the highmounted stop lamp.

S5.3.1.8 of FMVSS 108 specifies that no portion of the lens shall be lower than 3 inches below the rear window in case of a car other than convertibles if the lamp is mounted below the rear window.

Mazda is looking for the exact allowable areas where the lamp lens may be mounted, and shown below are two possible interpretations as seen by Mazda.

(TEXT OMITTED) SEE ILLUSTRATION IN ORIGINAL

Mazda would be very appreciative if you would advice us which is a correct interpretation or exact allowable lens location, if neither of these is correct.

Regards,