Interpretation ID: nht92-4.46

DATE: August 7, 1992

FROM: S. Watanabe -- Manager, Automotive Equipment Legal & Homologation Sect., Stanley Electric Co., Ltd.; Signature by P.P. F. Nakayama

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re: Location of R/C and CHMSL equipped on passenger cars

ATTACHMT: Attached to letter dated 8/21/92 from Paul J. Rice to S. Watanabe (A39; Std. 108)

TEXT:

We would like to ask you about the legality of 2 mounting locations (as shown in Fig. 1 and Fig. 2 in attachment) of R/C (tail & stop lamp) and CHMSL (center high mounted stop lamp) equipped on passenger cars for U.S. of less than 80 inches overall width.

In Fig. 1, for R/C, its height above road surface measured from center of item on vehicle at curb weight is 72 inches, and CHMSL is located 3 inches below the rear window. Wlile in Fig. 2, the height of R/C is 72 inches same as Fig. 1, CHMSL is located above the rear window and between two R/C located on each side of the vertical centerline.

We think the mounting locations of these lamps shown in Fig. 1 & 2 conform to the location requirements of table IV in FMVSS 108.

It would be very much appreciated for us to have your opinion about the legality of locations of these lamps.

(Drawings omitted)