ID: nht94-3.63

TYPE: INTERPRETATION-NHTSA

DATE: July 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Hellfried Sandig, Reitter & Schefenacker GMBH & Co. KG

TITLE: NONE

ATTACHMT: Attached to letter dated 6/6/94 from Hellfried Sandig to Richard van Iderstine

TEXT: This responds to your FAX of June 6, 1994, to Mr. Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

You present a drawing of a rear combination lamp incorporating one stop lamp and two taillamps. You have asked whether it is "necessary that we must have the ratio 5:1/3:1 between the stop and the tail lamp measurements in this arrangement?"

If the lamp is intended for use on narrower vehicles, the answer depends upon the distance between the optical axes of the stop and taillamp functions. SAE Standard J586 FEB84 Stop Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width is in corporated by reference in Standard No. 108. Paragraph 5.1.5.3 of J586 is the source of the ratio: "[w]hen a tail lamp is combined with the stop lamp, the stop lamp shall not be less than three times the luminous intensity of the tail lamp at any test p oint; except that at H-V, H-5L, H-5R, and 5U-V, the stop lamp shall not be less than five times the luminous intensity of the tail lamp." However, in a multiple compartment lamp such as yours, if "the distance between optical axes for one of the function s exceeds the dimensions specified in paragraph 5.1.5.2 [i.e., 560 mm] the ratio shall be computed for only those compartments or lamps where the tail lamp and stop lamp are optically combined." Although your combination lamp design combines the two func tions, your drawing indicates that they are not optically combined, and the ratio will not apply if the optical axes are more than 560 mm apart. The ratio will apply if the distance between the optical axis of the stop lamp and that of either taillamp i s 560 mm or less.

SAE Standard J1398 MAY85 Stop Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width is the standard incorporated in Standard No. 108 that applies to lamps used on wider

2

vehicles. Its paragraph 5.1.5.2 establishes the same 5:3 ratio (though not including H-5L in the five times ratio), but does not provide an exception based upon spacing of optical axes. Thus, if your lamp is designed for wider vehicles, the ratio appli es regardless of the spacing of the optical axes.

ID: nht95-2.27

TYPE: INTERPRETATION-NHTSA

DATE: April 10, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Bill Lieb -- Regional Sales Manager, ResTech

TITLE: NONE

ATTACHMT: ATTACHED TO 2/27/95 LETTER FROM BILL LIEB TO PHILIP RECHT (OCC 10797)

TEXT: Dear Mr. Lieb:

This is in reply to your letter of February 27, 1995. You report that "a manufacturer of sealed beam automotive head lamps . . . . was told by [an adhesive supplier] . . . . that D.O.T. 'approval' is required prior to changing the adhesive used on head lamps."

Subsequently, you were told by Blane Laubis of this agency "that D.O.T. does not test, approve, or specify any adhesives, but just verifies that the completed unit meets the prescribed standards, and passes the appropriate tests." You ask if this is corr ect.

Mr. Laubis is correct. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment establishes requirements that must be met by sealed beam headlamps. As you learned in your review, Standard No. 108 contains no spec ifications for adhesives. This means the manufacturer may choose the adhesive that appears best suited to ensuring that its particular sealed beam headlamp complies with the performance requirements of Standard No. 108. The approval of the agency is no t required. The agency frequently buys and tests all types of headlamps as part of its compliance enforcement program.

I hope that this letter is sufficient for your purposes.

ID: nht89-1.30

TYPE: INTERPRETATION-NHTSA

DATE: 03/02/89

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: ROBERT J. LATUS -- POSTMASTER U.S. POST OFFICE

TITLE: NONE

ATTACHMT: LETTER DATED 12/07/88 FROM ROBERT J. LATUS TO NHTSA, SUBJECT PRIMARY BRAKE LIGHT, OCC 2942

TEXT: Dear Mr. Latus:

This is in reply to your letter of December 7, 1988, regarding the functioning of stop lamps on a 1989 Oldsmobile Ciera car. You reported that the hazard warning lamps override the stop lamps on this model when both lamps are activated simultaneously. You have been informed that this is a new federal regulation. You have asked us to explain the regulation, reporting that foreign cars do not seem to present the problem you have identified.

At the outset, it may be helpful if we explain the applicable regulation, which is Federal Motor Vehicle Safety Standard 108. Under this standard, hazard warning systems are installed for use to indicate a disabled or slow moving vehicle in the roadway ahead. They ordinarily operate through the turn signal lamps, which can be either amber or red in color. In those rear lighting configurations where the turn signal lamps are red, they are frequently combined with stop lamps. (Combined lamps are those that share a common compartment and lens.) Under our standard, in a combined system the turn signals are required to take precedence over the stop lamps when both are activated. However, the rule does not specify a required order of precedence between the hazard warning lamps and the stop lamps. The stop lamps may be overridden by the hazard warning lamps when both are activated simultaneously, or the stop lamps may continue to operate and override the hazard warning signals. Our standard has allowe d either method of operation since it was first promulgated in 1968. Thus, there has been no change in the applicable regulation. As to your comment about foreign cars, it is our understanding that a large percentage of imported vehicles use amber rear turn signal and hazard warning systems, in which case the stop lamps and turn signal lamps are not combined. Therefore, both would operate independently when both are activated.

Since our standard allows both methods of operation, your dealer may legally modify the vehicle so that the primary stop lamps take priority if they and the hazard lamps are activated simultaneously. However, the

dealer may not legally alter the car is such a way that the alteration permits the primary stop lamps to override the turn signals if both are activated simultaneously.

We appreciate your interest in safety, and I hope that this answers your questions.

Sincerely,

ID: nht72-3.37

DATE: 03/22/72

FROM: AUTHOR UNAVAILABLE; E.T. Driver; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 3, 1972, concerning multiple audible warning requirements.

The audible warning requirements of Federal Motor Vehicle Safety Standards 114 and 208 can be met with the use of one system rather than two separate ones.

ID: 0797

Mr. Bill Lieb
Regional Sales Manager
ResTech
6120 East 58th Avenue
Commerce City, CO 80022

Dear Mr. Lieb:

This is in reply to your letter of February 27, 1995. You report that "a manufacturer of sealed beam automotive head lamps . . . was told by [an adhesive supplier]. . . that D.O.T. 'approval' is required prior to changing the adhesive used on head lamps."

Subsequently, you were told by Blane Laubis of this agency "that D.O.T. does not test, approve, or specify any adhesives, but just verifies that the completed unit meets the prescribed standards, and passes the appropriate tests." You ask if this is correct.

Mr. Laubis is correct. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment establishes requirements that must be met by sealed beam headlamps. As you learned in your review, Standard No. 108 contains no specifications for adhesives. This means the manufacturer may choose the adhesive that appears best suited to ensuring that its particular sealed beam headlamp complies with the performance requirements of Standard No. 108. The approval of the agency is not required. The agency frequently buys and tests all types of headlamps as part of its compliance enforcement program.

I hope that this letter is sufficient for your purposes.

Sincerely,

Philip R. Recht Chief Counsel ref:108 d:4/10/95

ID: nht69-2.33

DATE: 12/03/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Rootes Motors Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 10, 1969, concerning the requirement for turn signal lamps as specified in Federal Motor Vehicle Safety Standard No. 108. With respect to the installation requirements for front turn signal(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)(Illegible Line)

ID: nht74-1.10

DATE: 10/04/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 11, 1974 asking for an interpretation of paragraph S5.3.5 of Standard No. 105-75. You indicate that a prospective Nissan design uses a common indicator lamp to show both loss of fluid pressure and low brake fluid level. You ask if the indicator lamp lens may be labeled "Brake Failure."

The answer is no. If separate indicator lamps are used, Standard No. 105-75 allows words in addition to "Brake" to indicate the specific area where a problem may exist, e.g. an indicator lamp may be labelled "Brake fluid" to indicate a low level of fluid. However, if a lamp indicates more than one type of condition, paragraph S5.3.5 specifies that only a single word, "Brake," may be used. This alerts a driver in a general way that a problem exists somewhere in the brake system. We think the restriction of S5.3.5 preferable for most circumstances. In the configuration you propose for example, the word "Failure" would not accurately describe a low level of brake fluid.

We appreciate your continued interest in vehicle safety.

Yours truly,

ATTACH.

September 11, 1974

Richard B. Dyson -- Acting Chief Council, National Highway Traffic Safety Administration

Dear Mr. Dyson:

This is to ask your interpretation of S.5.3.5, indicator lamp requirement of MVSS 105 - 1975, which states:

"If separate indicator lamps are used for one or more of the various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure', 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used."

As I explained to Mr. Vinson on the phone, Nissan's 1976 model will be equipped with two sensors, brake fluid level sensor and pressure loss sensor (if one of the two sensors or both operate, the indicator lamp turns on). Therefore, since we cannot use either the word "Brake Pressure" or "Brake Fluid" as requested in the standard, we would like to use the word "Brake Failure" instead.

Would you kindly advise us as to whether or not this word "Brake Failure" is acceptable; and if not, please recommend a suitable word for our use. Your cooperation would be greatly appreciated.

Thank you.

Very truly yours,

NISSAN MOTOR COMPANY, LTD.; Tatsuo Kato -- Staff, Safety

ID: 1985-01.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/04/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Brian Gill -- Senior Manager, Certification Dept., American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Brian Gill Senior Manager Certification Department American Honda Motor Co., Inc. P.O. Box 50 Gardena, California 90247

This is in response to your letter of May 25, 1984, asking for an interpretation of Motor Vehicle Safety Standard No. 108. Table IV specifies that the minimum horizontal separation distance "(centerline to centerline of lamp)" for rear turn signal lamps on motorcycles is 9 inches. You have asked whether the "centerline" refers to the distance between the lens centers, between the centers of the effective projected luminous areas, or between the bulb centers.

You asked for confirmation of your belief that the proper interpretation is found in the referenced SAE Standard, J588e, which contains the language "Optical axes (filament centers)," implying that the correct distance is that between the "bulb centers" as you term it.

We find no direct correlation between the phrases "centerline to centerline of lamps" and "optical axis (filament center) ." The lamp is a device emitting light whereas "optical axis (filament center)" does not refer to the lamp but only to a portion of its light-producing component. As that phrase is used in SAE J588e, it defines the method of measuring distances between bulbs in multi-compartment lamps for the purpose of testing for photometric requirements (paragraph 3.1), or in measuring the separation of the turn signal from the headlamp (paragraph 4.2, where, incidentally, it is expressed as the distance between filament and a lamp component, the retaining ring).

Taken literally, "centerline to centerline of lamps" in our view means the distance between lens centers. In the response to petitions for reconsideration of the center high-mounted stoplamp amendment (May 17, 1984), the question was asked whether the "center" of the lamp was its geometric center, its optical center, or the center of the bulb filament. The agency replied that the center of the lamp is the geometric center. Since the purpose of the minimum separation requirement is to insure that the turn signal is perceived as such, we believe that the correct interpretation of "centerline to centerline" is a measurement from the geometric center of one lamp to the geometric center of the other lamp. The geometric center would be anonymous with the term "geometric centroid of lens" as used in SAE J1221 Headlamp-Turn Signal Spacing. Sincerely,

Frank Berndt Chief Counsel

ID: nht78-2.11

DATE: 07/10/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Hon. Paul Trible - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the letter (enclosed) you received from your constituent Mr. Randy Churaman of Hampton, Virginia, concerning plexiglass covers for headlights.

The National Highway Traffic Safety Administration (NHTSA) in 1972 proposed rulemaking to allow fixed plastic covers over motor vehicle headlights. However, during the comment period of the proposed rule-making some controversial items that were raised regarding fixed plastic headlight covers initiated concerns with respect to motor vehicle safety. These concerns were that: (1) moisture condenses inside the plastic covers and greatly increases headlight glare to oncoming traffic, (2) the plastic covers get scratched, thus reducing headlight output and increasing headlight glare at the same time, (3) plastic headlight covers have to be removed to mechanically aim headlamps, which becomes quite expensive to the vehicle owner and (4) correct aim of headlights is often made incorrect when installing fixed plastic headlight covers. Finally, the change in air drag by use of plastic headlight covers is extremely small since the air drag is primarily related to the overall frontal area projection of the vehicle.

Because of the foregoing disadvantages, and no major advantage to fixed plastic headlight covers other than styling, Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment, prohibits fixed plastic covers over headlamps. Specifically, FMVSS No. 108 references SAE Standard J580a, which states in part . . . "When in use, a headlamp shall not have any styling ornament or other feature, such as a glass cover or grill, in front of the lens." There is, however, no prohibition on the installation of original equipment retractable clear plastic headlamp concealment devices on newly manufactured motor vehicles.

I trust the foregoing is fully responsive to your inquiry.

ENC. CONSTITUENT'S LETTER

EXECUTIVE TOWER, BOX 59 2101 EXECUTIVE DR. HAMPTON, VA 23666

Dear Mr. Trible

I own a Datsun 280 Z sports car which has a very aerodynamic front end except for the cutouts for the headlights (see sketch). In other countries there are clear plexiglass covers available for the headlights, which fit over the cutouts, and complete the aerodynamic lines. In this country these covers are illegal for reasons which are beyond my comprehension since they would reduce the air drag of the car, and therefore give better gas milage. I would like to see the law changed to permit the use of these headlight covers, or know why they are illegal.

Randy Churaman

(Graphics omitted)

ID: nht95-4.86

TYPE: INTERPRETATION-NHTSA

DATE: November 28, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Phyllis Armstrong -- General Sales Manager, Saturn of Puyallup, Inc., Washington

TITLE: NONE

ATTACHMT: ATTACHED TO 5/17/95 LETTER FROM Phyllis Armstrong to Phillip Reckt; Also attached to 7/20/89 letter from Kathleen DeMeter to B.L. Swank

TEXT: Dear Ms. Armstrong:

This is in response to the letter in which you requested this office to confirm in writing that the information you received from Mr. Richard Morse, Chief of the Odometer Fraud Staff of the National Highway Traffic Safety Administration (NHTSA), concerni ng the proper completion of odometer disclosure statements for Saturn vehicles that have been towed. The question arises because the odometer on the Saturn is designed not to register miles when the vehicle is being towed.

NHTSA's interpretation of the Truth in Mileage Act of 1986 ("TIMA," 49 U.S.C. Chapter 327) and the regulations implementing TIMA (49 CFR Part 580) is that when a vehicle has been towed, but its odometer is not capable of registering towed mileage, the pr oper way to complete the odometer disclosure statement is to record the number of miles showing on the odometer. It is permissible in such a situation for the transferor to certify that this number is the actual mileage on the vehicle, assuming there ar e no other reasons to believe that the reading on the odometer does not reflect actual miles driven.

The situation you describe is comparable to that in which the odometer is disconnected and the drive wheels of the vehicle are off the pavement while it is being towed. In a 1989 interpretation letter, the Chief Counsel of NHTSA stated that when the veh icle is being towed with its drive wheels off the pavement and the odometer disconnected, the mileage driven while being towed does not count, and need not be added to the mileage showing on the odometer. That letter also stated that the transferor may c ertify in this circumstance that the mileage on the odometer, exclusive of the towed mileage, is the actual mileage. I have enclosed a copy of that letter for your information.

P2

I hope you find this information helpful. If you have any further questions on Federal odometer disclosure requirements, you may contact Mr. Morse or Ms. Eileen Leahy, an attorney on my staff, at the above address. You may reach Ms. Leahy at (202) 366- 5263, and Mr. Morse at (202) 366-4761.

Sincerely,