ID: nht78-2.13

DATE: 06/02/78

FROM: AUTHOR UNAVAILABLE; J. J. Leven, Jr.; NHTSA

TO: Minnesota State Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Jim Downey of our regional office has forwarded for reply your letter of May 3, 1978, in which you asked whether a single beam headlighting system is permissible on mopeds.

The answer is yes. The portion of SAE Standard J584 that you have quoted only establishes an option to the specific requirements of J584. Table 1 of J584 permits motor driven cycles to be equipped with a single (upper) beam headlamp. We consider mopeds to be "motor driven cycles" as defined by 40 CFR 571.3(b) and J584 as they are invariably powered by a motor developing less than 5 horsepower.

I hope this answers your question.

SINCERELY

STATE OF MINNESOTA DEPARTMENT OF PUBLIC SAFETY

May 3, 1978

Jim Downey National Highway Traffic Safety Administration Regional Office

Dear Mr. Downey:

We are having difficulty in determining whether FMVSS 108 permits single beam road lighting for mopeds.

Page 32914 of Federal Register 39, No. 178, dated September 12, 1974, contains a reference to NHTSA exploring forward lighting needs of motor-driven cycles and indicates that a decision would be made as to whether a reduced minimum standard would be appropriate.

We are unable to locate any writings as to the conclusions arrived at beyond that point other than reference in FMVSS 108 (S4.1.1) that ". . . each vehicle shall be equipped with at least the number of lamps . . . specified in Tables I and III, as applicable. Required equipment shall be designed to conform to the SAE Standards or Recommended Practices referenced in those tables."

Table III indicates one (1) white headlamp for motorcycles and cites SAE Standard J584. This standard (J584) contains the general requirement of ". . . one 7-inch sealed beam unit or one 5 3/4 inch Type 1 and one 5 3/4 inch Type 2 sealed beam units meeting the requirements of SAE J579 may be used on a motorcycle or a motor driven cycle."

Since compliance with either option of J584 results in having a high beam and a low beam we are unable to conclude that one (1) single beam headlamp on a moped constitutes compliance with FMVSS 108.

Our concern arises from the fact that our state recently adopted moped legislation requiring the same lighting equipment as is required of motorcycles and we must give due consideration to federal requirements in view of the fact that Minnesota law requires motorcycles to have both an upper beam and a lower beam.

Your assistance in this matter is deeply appreciated.

Colonel James C. Crawford Chief Minnesota State Patrol

ID: nht78-2.14

DATE: 08/23/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: Nippondenso Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 10, 1978, to Mr. Vinson of this office requesting confirmation of interpretations of Paragraph S4.7 of Motor Vehicle Safety Standard No. 108.

This confirms your interpretations.

Paragraph S2, Application states the coverage of the standard: to specified vehicle types "and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies" i.e. those vehicles manufactured on or after January 1, 1972. The equipment items listed in Tables I and III are required motor vehicle lighting equipment, and any item manufactured as a replacement for one of these items that has been original equipment on 1972 or later model vehicles, must meet Standard No. 108's requirements and be so certified.

Paragraph S4.7 allows certification by means of a DOT symbol placed on the item itself. No specific design or size is required. The manufacturer may certify by other means as well, specifically those set forth for all equipment items covered by a standard, in Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403): "a label or tag on [the] item or on the outside of a container in which such item is delivered". We would view an indelible stamp on the container as "a label" within the meaning of Section 114 if Nippondenso wished to certify by this means.

I have no other suggestions regarding use of the DOT symbol, except that it should be of a size and in a location sufficient to readily identify the item as meeting Federal requirements, thereby avoiding any possible misunderstanding.

Sincerely,

August 10, 1978

Taylor Vinson Senior Staff Attorney Office of the Chief Counsel Department of Transportation

Dear Mr. Vinson:

This letter is to confirm our telephone conversation of August 8, 1978 in which I requested information pertaining to Federal Motor Vehicle Safety Standard No. 108, Section 4.7.

Question: Is the DOT symbol required on replacement equipment?

Answer: The DOT symbol can be used on either of the following: 1. Stamped on the equipment.

2. Label or tag attached to the equipment stating that the equipment is certified by DOT.

3. Stamped on the container in which the equipment is packaged.

Question: Is there any specific design or size required when using the DOT symbol?

Answer: There is no specific design or size required by DOT.

Question: Please define replacement equipment?

Answer: Replacement equipment is defined as any item of equipment which replaces original equipment that is required to meet compliance specifications set by DOT.

The above information you supplied was transmitted to our head office in Japan. However, they would appreciate the above information in a letter form signed by you. They have also requested any additional information which will be helpful to them in understanding the requirements regarding the DOT symbol.

Thank you for your kind assistance.

Anna Racanelli Assistant General Manager

ID: nht78-2.15

DATE: 03/15/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Vetter Fairing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 1, 1978, on motorcycle headlighting.

You have asked whether the prohibition in SAE J580a Sealed Beam Headlamp against headlamp covers applies to a motorcycle. You have also asked the reason for the prohibition.

SAE J580a Sealed Beam Headlamp is incorporated by reference in Table III of Standard No. 108 as one of the standards applicable to headlamps for use on passenger cars, and on multipurpose passenger vehicles, trucks, and buses whose overall width is less than 80 inches. One of the SAE standards incorporated by reference for motorcycle headlighting is J584 which, as an option, allows motorcycles to be equipped with headlamps "meeting the requirements of SAE J579" (i.e. passenger car sealed beam headlamps). There is no reference in J579a to J580a, and we therefore do not read the prohibition against headlamp covers as applying to motorcycles equipped with sealed or unsealed headlamps.

The reason for the prohibition is the degradation in Light output that can result from condensation under unsealed glass covers or from obscuration by grilles in front of the lens.

SINCERELY,

Vetter Fairing Company

February 1, 1978

Office of Chief Council Joseph J. Levin, Jr. National Highway Traffic Safety Admin.

Dear Sir:

After reviewing Title 49 Code of Federal Regulations 571.108, Motor Vehicle Safety Standard Number 108, Lamps, Reflective Devices and Associated Equipment, I find a need to have several points of this regulation, relevant to our business, clarified and interpreted per your office.

Table III, Required Motor Vehicle Lighting Equipment, Item - Headlamps, references the applicable SAE standard or recommende practice for passenger cars, multipurpose passenger vehicles, trucks and buses to be, in part, SAE J580a, June 1966. Contained within SAE J580a, sealed beam headlamp, under General Requirements it states "A headlamp, when in use, shall not have any styling or other feature, such as a glass cover or grille in front of the lens."

Is it correct to assume that this prohibition does not apply to a motorcycle or to a motorcycle with attached side car? Also would you please state the reason/s why passenger cars are prohibited from having any styling or other feature, such as a glass cover or grille in front of the lens when a headlamp is in use?

Table III, Required Motor Vehicle Lighting Equipment, Item - Headlamps, references the applicable SAE standard or recommended practice for motorcycles to be, in part, SAE J584, April 1964. Standard SAE J584, motorcycle and motor driven cycle headlamps makes no mention of any prohibition of having any styling or other feature, such as a glass cover or grille in front of the lens when a headlamp is in use.

Is it correct to infer that it is legal and within the scope of Motor Vehicle Safety Standard Number 108, to have styling or other feature, such as a glass cover, or plastic cover or grille in front of the lens when a headlamp is in use on a motorcycle or on a motorcycle with attached side car?

It is in the intent of Vetter Fairing Company as a manufacturer of motorcycle accessories to conceive, research, design, produce, manufacture and market motorcycle accessories which meet or exceed all Federal Motor Vehicle Safety Standards of the National Highway Traffic Safety Administration, Department of Transportation.

Your review of any and all applicable regulations relevant to our business is appreciated and your interpretation of such regulations pertaining to the above questions is requested so that we can meet our obligations, to consumers, to manufacturer motorcycle accessories which are safe and which comply with all Federal Motor Vehicle Safety Standards.

W. W. Schwartz Technical Engineer Research & Development Dept.

cc: C. VETTER C. PERETHIAN

ID: nht78-2.16

DATE: 06/02/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: State of Delaware

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 18, 1978 which asks the following questions:

"Is there a Motor Vehicle Safety Standard which requires all motorcycles to be equipped with turn signals, other than those expressly exempted under FMVSS 108 (whose speed atainable in 1 mile is 30 mph or less) S4.1.1.26?"

Yes. Paragraph S4.1.1 of Standard No. 108 requires, in part, that motor vehicles be equipped with the lamps specified in Table III. Turn signal lamps are required for motorcycles under Table III.

"Does the standard apply to only highway-use vehicles with trail-bikes exempted?"

Yes. The motorcycles covered by Standard No. 108 must be "motor vehicles" in the first instance, in order to be subject to the regulatory authority of the National Traffic and Motor Vehicle Safety Act. A "motor vehicle" is one "manufactured primarily for use on the public streets, roads and highways". This would exclude a trail bike unless its manufacturer had certified it to meet all applicable Federal motor vehicle safety standards, indicating his intent that it be used on-road as well as off-road.

We are enclosing a copy of Standard No. 108 as you requested.

SINCERELY,

STATE OF DELAWARE DEPARTMENT OF PUBLIC SAFETY

May 18, 1978

Joseph J. Levin, Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin:

The Delaware Division of Motor Vehicles would appreciate your assistance in determining the following:

Is there a Motor Vehicle Safety Standard which requires all motorcycles to be equipped with turn signals, other than those expressly exempted under FMVSS108 (whose speed attainable in 1 mile is 30 mph or less) S.4.1.1.26?

We would appreciate a copy if such a standard exists. Also, does the standard apply to only highway-use vehicles with trail-bikes exempted?

Thank you for your assistance in this matter.

Robert J. Voshell Director, Motor Vehicle Division

ID: nht78-2.17

DATE: 06/08/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 4, 1978, to Howard Dugoff requesting confirmation of two interpretations of Motor Vehicle Safety Standard No. 108. You have cited our letter of December 29, 1976, to your Mr. Weil as support for your views.

With respect to your first concern, you have stated your understanding that in a multiple compartment taillamp the manufacturer has the option of using one or more compartments to meet the minimum photometric requirements specified for taillamps, but when the intensity ratio of the turn signal lamp to the taillamp is computed, the ratio must be determined with all taillamp compartments lighted.

As we interpret Standard No. 108's requirements for taillamps (SAE Standard J585d, Tail Lamps (Rear Position Light), August 1970), a single compartment lamp may be used as a taillamp, but if a multiple compartment lamp or multiple lamps are used to meet the photometric requirements, S3.1 of J585d requires that the combination of the compartments or lamps must be used to meet the photometric requirements for the corresponding numbers of lighted sections (Table 1, J585d) in those instances where the distances between filament centers do not exceed 22 inches for two-compartment or lamp arrangements, and 16 inches for three compartment or lamp arrangements. If these distances are exceeded, each compartment or lamp must comply with the photometric requirements for one lighted section. Therefore your interpretation is incorrect that a manufacturer may use only one compartment of a multi-compartment lamp when considering compliance with the photometric requirement for taillamps.

Your second concern is the requirement for multiple lamps in excess of three. You have noted that Table 1 of SAE J585 makes no provision for candlepower requirements where there are more than three lighted sections. Noting that the maximum candlepower permissible rises in increments of 5 per section (15 for one section, 20 for two sections, 25 for three sections) you have asked for confirmation of your opinion that "it appears logical that the allowable candlepower for a four compartment system should be 30 candlepower."

Standard No. 108 does not specify requirements for compartments or lamps in excess of three. If you wish to use a four compartment or lamp system you are legally free to distribute the candlepower as you deem appropriate. Accordingly we have no objection to your belief that 30 candlepower is allowable provided that the multiple compartment lamp or multiple lamp arrangement meets all other requirements of J585d.

SINCERELY,

CHRYSLER CORPORTION May 4, 1978

Howard Dugoff Deputy Administrator National Highway Traffic Safety Administration

Dear Mr. Dugoff:

Re: MVSS 108 - Requirements for Multiple Cavity Tail Lamps or Multiple Tail Lamps

The NHTSA provided interpretations of certain requirements of MVSS No. 108 as applied to photometric test requirements for multiple cavity and multiple lamp configurations in a letter of December 29, 1976. Our further review of MVSS No. 108 has uncovered two additional points pertaining to tail lamps on which we would appreciate your advice.

I. Photometric Requirements

MVSS No. 108 incorporates by reference SAE Recommended Practice J585d which specifies the photometric requirements for tail lamps. Paragraph 3.1 of SAE J585d provides that multiple compartment lamps (or multiple lamps) may be used to meet the photometric requirements for a tail lamp. Additionally, paragraph 3.1 describes how multiple compartments or multiple lamps are to be treated if they are in fact used to meet the photometric requirements for a tail lamp.

Our understanding of these requirements is that the manufacturer has the option to use one or more compartments of a multi-compartment lamp (or one or more lamps of a multiple lamp system) to meet the photometric requirements specified. In cases where the manufacturer uses only one compartment of the lamp to meet the photometric requirements for a tail lamp, compartments or lamps not used are considered as "supplemental lamps" and are not required to meet test requirements except for the differential values discussed in the next paragraph.

The above is consistent with your letter of December 29, 1976 that stated that the NHTSA interprets MVSS No. 108 as requiring that the ratio of the turn signal lamp to the tail lamps must be computed with all the lamps lighted when multiple compartment and multiple lamp configurations are used. Such a requirement, of course, maintains the differentiation between the turn signal and the tail lamps.

The net result of the above as we interpret the regulation is that where there is a multiple compartment tail lamp (or where there are multiple tail lamps) it is necessary to measure the output of all tail lamps in determining the ratio between tail lamp intensity and turn signal intensity. However, it is permissible to use only one compartment of a multi-compartment lamp (or one lamp from a multiple lamp system) when considering compliance with the photometric requirements for tail lamps; other lamps or compartments would be merely "supplemental."

II. Multiple Lamps in Excess of Three

Section 3.1 of SAE J585d further provides that if one or more lamps of a multiple compartment lamp (or multiple lamps) is used to meet the prescribed photometric requirements for tail lamps the maximum candlepower for the combination of all the compartments (or lamps) must not exceed those set forth in Table 1 of SAE J585d for the corresponding number of lighted sections. The candlepower values specified in Table 1 are 15 for a one lighted section, 20 for two lighted sections, and 25 for three lighted sections. Use of lamps with four or more compartments or lamps are not prohibited. However, the Table does not contain a progression of maximum candlepower values for lamps with additional compartments beyond three. While not specified in the standard, in keeping with the progression of higher values in the Table for one, two, and three compartment lamps, i.e., 15, 20, and 25 candlepower, it appears logical that the allowable candlepower for a four compartment system should be 30 candlepower.

We would appreciate your confirmation of our interpretation of these provisions of MVSS No. 108 set forth in Section I and Section II above.

Thank you for your assistance.

R. O. Sornson Manager Environmental Relations

ID: nht78-2.18

DATE: 12/04/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Department of the Army

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 13, 1978, to the Administrator questioning whether certain trucks procured by your Command comply with paragraph S4.5.4 of Federal Motor Vehicle Safety Standard No. 108.

That paragraph states "The stop lamps on each vehicle shall be activated upon application of the service brakes." You wrote that "when the hazard warning lights are activated the stop lamp cannot be activated upon application of the service brakes." The system you describe would be in compliance with Standard No. 108, if the stop lamps and signal lamps are optically combined, for the following reasons. Paragraph S4.4.1 allows combination of a stop lamp with a turn signal lamp (which provides the hazard warning signal). Paragraph 4.2 of SAE Standard J586c Stop Lamps, August 1970 (incorporated by reference in Standard No. 108 as the operative standard for stop lamps) requires that "When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing."

This, of course, means that in a combination lamp the stop signal cannot be given while the hazard warning signal is being operated. If the Army deems it desirable it could require a different circuitry in combination lamps by which the stop lamps and hazard warning signal lamps could operate simultaneously, as military vehicles need not conform to Federal safety standards (49 CFR 571.7(c)).

Because several jurisdictions require slow-moving vehicles to use the hazard lamps while in motion, I am asking our Office of Rulemaking to review this prohibition. Thank you for bringing this matter to our attention.

SINCERELY,

DEPARTMENT OF THE ARMY

US ARMY TANK-AUTOMOTIVE MATERIEL READINESS COMMAND

NOVEMBER 13, 1978

Administrator National Highway Traffic Safety Admin

Dear Ms. Claybrook

Reference is made to FMVSS 108, paragraph S4.5.4.

Reference paragraph states "The stop lamps on each vehicle shall be activated upon application of the service brakes."

Inspection of the lighting system in some commercial trucks recently procured by this Command disclosed that when the hazard warning lights are activated the stop lamp cannot be activated upon application of the service brakes.

While it is recognized that the primary purpose of hazard warning lights is to warn approaching traffic of a disabled vehicle, several states require the use of hazard warning signal for slow moving vehicles, i.e, NY Thruway, and Pennsylvania Turnpike. Application of the service brakes under this condition would not activate the stop lamps to warn following traffic.

Request this office be provided the DOT position as to whether or not the system described above meets the requirements of FMVSS 108, S4.5.4.

ROBERT J. SHIROCK Safety Director

ID: nht78-2.19

DATE: 05/22/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1978 asking whether there is any legal objection to Volvo's installation of red rear fog lamps on passenger cars it sells in the United States.

As you have noted, "the only possible objection" to these lamps is the prohibition of S4.1.3 of Motor Vehicle Safety Standard No. 108 against the installation of lamps that impair the effectiveness of lighting equipment mandated by the standard. We have no basis for disagreeing with your opinion that the red "rear fog lamps do not impair the effectiveness of other lighting equipment." However, the lamps would be subject to the laws of the individual States.

SINCERELY,

Volvo of America Corporation

May 3, 1978

Joseph J. Levin, Jr. Chief Counsel Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Levin:

Re: Request for Interpretation, FMVSS #108

An item which has met with some popularity on the European market is the red rear fog lamp. This is a red lamp controlled by a separate switch on the dashboard and operated at the driver's option. The purpose of this lamp is to provide improved visibility in fog or other adverse weather.

Red rear fog lamps are standard equipment on Volvo 262/264 models for all EEC countries. These lamps are made to comply with EEC directives regarding installation and photometrics. Enclosed for your information are covering installation of lighting (Section 4.11 covers rear fog lamps); and covering photometric requirements of rear fog lamps.

These lamps do not qualify as tail lamps since they are not controlled by the same switch as the headlights. In our opinion, they would not, then, be subject to the maximum tail lamp candlepower restrictions of FMVSS #108, S4.1.1. This section also states that each vehicle be equipped with at least the number of lamps specified in the section.

As we read FMVSS #108, the only possible objection to these lamps might arise from Section 4.1.3 which states that "no additional lamp, reflective device, or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard". In our opinion, rear fog lamps do not impair the effectiveness of other lighting equipment. Furthermore, we believe that these lamps will greatly enhance vehicle safety. We feel that the spirit of the law is to improve vehicle visibility which these lamps will in fact do.

Please advise us as to whether you agree with our interpretation.

If I can be of any assistance in this matter, please feel free to call.

VOLVO OF AMERICA CORPORATION Product Planning and Development

William Shapiro, P.E. Manager, Regulatory Affairs

[EEC INFORMATION OMITTED]

ID: nht78-2.2

DATE: 12/08/78

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: AMF Incorporated

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. R. W. Fink AMF Incorporated 3700 W. Juneau Avenue P.O. Box 653 Milwaukee, Wisconsin 53201

Dear Mr. Fink:

This is in response to your letter of November 7, 1978, concerning the lettering permissible under Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your conversation with Mr. Schwartz of my office.

Paragraph S4.3.1 of the standard provides that the type face utilized for the vehicle identification number shall consist of capital, sans characters. Although the "1" in the "posident" type face which you propose to use has a slight at the top, the type face would still be considered sans . Consequently, there is no bar to utilizing "posident" if you desire.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

November 7, 1978

Mr. Frederic Schwartz, Jr. Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

Dear Mr. Schwartz:

On October 19, 1978 a member of my staff, Harvey Medinger, called you to determine if special stamping tools (typefaces) such as the "Posident" were permissible for stamping the Vehicle Identification Number (VIN) required by Standard No. 115. Your response was generally favorable; but, you requested a drawing of the Posident typeface. Enclosed is the requested drawing.

Due to the high theft rate of our cycles, we wish to continue using a unique typeface not readily available to the general public.

The Posident characters meet all requirements of Standard No. 115; except, the sans requirement. Per Standard No. 115, letters I, O and Q would not be used.

Please review this request and inform us of your decision.

Very truly yours,

R. W. FINK Mgr./Information Systems

RWF/meo

Enclosure

ID: nht78-2.20

DATE: 05/18/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Mohs Seaplane Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 5, 1978, asking "what is necessary for the rewriting of [Motor Vehicle Safety Standard No.] 108 to include my . . . system for vehicle identification." As you have described this reflective device, it is a polyvinyl extrusion in which is placed polyester tape which "becomes a continuous reflector down the side of a vehicle - amber toward the front, red on the rear half of the vehicle and red across the back." You state that in your experimental installation you are "retaining the 3" spot reflectors as required in Standard 108."

If your material conforms to Federal Specification L-S-300 and, as used on the vehicle, meets the performance standards in Table 1 of SAE Standard J594d, "Reflex Reflectors," March 1967, it could be used as the front and rear reflex reflectors required by Standard No. 108. However, if it does not meet this specification, Standard No. 108 would not prohibit the sale and installation of your system as original equipment, or as an aftermarket accessory, provided it is supplementary to the side and rear reflectors required by Standard No. 108. Thus, no Federal "approval" of your system is required. A change in Standard No. 108 is required only if you believe your system should be mandatory on all motor vehicles. In the event you wish to petition for such an amendment of Standard No. 108, I enclose a copy of our rulemaking procedures.

YOURS TRULY,

Mohs Seaplane Corporation

May 5, 1978

Chief Consul, NHTSA

Dear Sir,

I was advised by Mr. Carderelli of the American Association of Motor Vehicle Administrators that I should request approval of a new reflective device I have for motor vehicles which consists of a poly-vinyl extrusion in which is placed polyester metallic tape and into which is slid computer designed and computer milled reflectors so the final result becomes a continuous reflector down the side of a vehicle -- amber toward the front, red on the rear half of the vehicle and red across the back.

This invention is an adaptation of the very advanced reflectors used in the space age to assist solar cells in their recharging efforts on satelites, and adaptation to motor vehicle use from the railroad crossing buck use portrayed in Governor Martin Schreiber's Safety Reporter enclosed (please note page 2). We are just beginning the installation on 50 semi-trailers here in Madison as an accessory item and retaining the 3" spot reflectors as required in standard 108. Our photometric result is superior to acrylic reflectors used in the past and reflective sheeting, etc.

Please let me know what is necessary for the rewriting of 108 to include my (I believe) superior system and safer system for vehicle identification. Of course we have many other uses for something that performs as to other reflectors as the super ball does to a conventional ball. We have a patent pending number. Piers, gunnels of boats, mail box posts, railway crossing gates, loading docks, etc. have been experimented with.

Last September I saw Mr. Marx Elliott in your building on this same matter and also have talked with Mr. Bill Eason. Since sales are just now really taking off government approval is essential and certainly desired. In the interests of safety -- all selfish profit motives aside -- I think we have something of interest here. I will gladly send samples if you so request to above address.

Please also send proceedures to follow to above address.

Bruce Baldwin Mohs, Pres. MOHS SEAPLANE CORPORATION

[ENC. OMITTED]

ID: nht78-2.21

DATE: 07/19/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: Lighting and Optic Laboratory

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 8, 1978, to Mr. Vinson of this office concerning the version of SAE J567, Bulb Sockets, applicable as a subreferenced standard to Federal Motor Vehicle Safety Standard No. 108.

The SAE standards which are specified in Standard No. 108 are cited by a number and letter to indicate the applicable version. These directly referenced SAE standards often subreference other SAE standards by inclusion of such terms as "reference is made to SAE J " or "reference SAE J " in which case, unless otherwise specified in Standard No. 108, the subreferenced standard is the version contained in the 1970 SAE Handbook (See paragraph S5.1 of Standard No. 108).

The subreferenced SAE standard closest in subject matter to J567 is J573d, "Lamp Bulbs and Sealed Units", December 1968. By NHTSA interpretation J573 is not exclusive, and other bulb designs including tubular type bulbs are permitted which are not included in SAE J573. There is no subreferenced notation to SAE J567 contained in SAE J573d. Further, although the agency issued an interpretation in 1968 indicating that SAE Standard J575d, Tests for Motor Vehicle Lighting Devices and Components, August 1967, referenced J567, that statement was incorrect and J575d contains no such reference. Therefore SAE J567 is not a subreferenced standard in Standard No. 108. When an SAE Standard is not referenced or subreferenced by a Federal Standard, compliance with it is voluntary, and you may therefore use (or not use) SAE J567 or any version thereof as you choose, as long as the assembled lamp complies with Standard No. 108.

SINCERELY,

FIAT SETTORE AUTOMOBILE

8th May, 1978

TAYLOR VINSON Office of Chief Counsel National Highway Traffic Safety Administration

FMVSS N. 108 - Lamps, Reflective devices and Associated equipment.

Dear Mr. Vinson,

on behalf of Italian Electrotechnical Committee (CEI) I pose to you a question regarding SAE Standard related to bulb and socket.

The International Electrotechnical Commission (IEC) issued a number of Standard sheets applicable to bulb base, socket, and lampholders for automotive use.

The Italian Committee made a reserve with explication that IEC dimension and tolerances are not compatibles with ones stated in SAE Standard J 567b.

In many cases the lighting devices for motor cars are the same for European market and for North-American market. Car manufacturers and lamp manufacturers obviously wishes to use only one type of lampholder, for internal standardization, cost reduction.

The IEC/Technical Committee 34 (Lamp and holder) affirmed that SAE J 567 b is not longer applicable because she is obsolete, replaced by J 567 c and the applicable SAE Standard for lighting equipment reported only the reference to "SAE Standard J 567" without any indication of edition.

Finally, the Chairman of IEC/TC 34, Mr. E.M. Kooker (G.E. - Lamp Division) suggested us to present the question directly to NHTSA.

The questions are the following:

"In the case of SAE Standard J 567, which is the edition applicable: the J 567 b, current at first publication of Standard 108 (1966), or the new one, J 567 c (1970)?

If either "b" or "c" are applicable, and the lamp manufacturer chose the "c" edition, how he can demonstrate the compliance with the Standard?

Should he declare that the lampholder would be checked with the gages of tables 1 and 2 in J 567 c and not with a caliper or other instrument?".

We think that your explanation will be very useful in our daily work for motor vehicle safety.

(G. Bertella) Chief, Lighting and Optic Laboratory