ID: nht95-6.19

TYPE: INTERPRETATION-NHTSA

DATE: August 22, 1995

FROM: SABURO INUI -- VICE PRESIDENT, TOYOTA MOTOR CORPORATE SERVICES OF NORTH AMERICA, INC.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Request For Interpretation FMVSS 114 Theft Prevention, Final Rule Vehicle Rollaway Test Procedure [Docket No. 1-21; Notice 13]

ATTACHMT: ATTACHED TO 10/13/95 LETTER FROM JOHN WOMACK TO SABURO INUI (A43; STD. 114)

TEXT: Dear Mr. Womack;

Toyota would like to request an official interpretation concerning the automatic transmission park position test procedure outlined in the in the FMVSS 114 final rule, as given in the June 7, 1995 Federal Register.

Subsequent to publishing the final rule, NHTSA issued an interpretation to General Motors describing the test procedure as a "static" test, i.e. dynamic body motions were not to be included in the overall measurement of vehicle motion. It is also our understanding that the measurement is to be taken beginning at the moment before the service brake is released. Sections S5.2(e) and S5.3(b) both describe the test procedure as follows; (step numbers are added for clarity)

NHTSA procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Move the shift mechanism to the "park" position Step 5. Apply the service brake Step 6. Release the parking brake Step 7. Release the service brake Step 8. Verify that the vehicle movement was less than or equal to 150 mm.

As written, step 2 of this procedure requires application of the service brake and step 5 requires the same. But there is no action to release the service brake. We believe the intention of the procedure either requires a release of the service brake between steps 2 and 5, or step 5 should be eliminated (meaning the service brake is only released to begin the measurement).

Therefore, we are proposing the following revised procedure;

Toyota's Proposed Procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Release the service brake Step 5. Move the shift mechanism to the "park" position Step 6. Apply the service brake Step 7. Release the parking brake Step 8. Release the service brake Step 9. Verify that the vehicle movement was less than or equal to 150 mm

Obviously, if the vehicle is not equipped with a parking brake, Steps 4, 6, and 7 of Toyota's procedure (or Steps 5 and 6 of NHTSA's procedure) would be eliminated.

Therefore, we request an interpretation of whether Toyota's proposed procedure fulfills the intention of NHTSA's test requirement.

Should you have any further questions, please contact Mr. Chris Tinto of my staff at (202) 775-1707.

ID: nht95-3.96

TYPE: INTERPRETATION-NHTSA

DATE: August 22, 1995

FROM: SABURO INUI -- VICE PRESIDENT, TOYOTA MOTOR CORPORATE SERVICES OF NORTH AMERICA, INC.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Request For Interpretation FMVSS 114 Theft Prevention, Final Rule Vehicle Rollaway Test Procedure [Docket No. 1-21; Notice 13]

ATTACHMT: ATTACHED TO 10/13/95 LETTER FROM JOHN WOMACK TO SABURO INUI (A43; STD. 114)

TEXT: Dear Mr. Womack;

Toyota would like to request an official interpretation concerning the automatic transmission park position test procedure outlined in the in the FMVSS 114 final rule, as given in the June 7, 1995 Federal Register.

Subsequent to publishing the final rule, NHTSA issued an interpretation to General Motors describing the test procedure as a "static" test, i.e. dynamic body motions were not to be included in the overall measurement of vehicle motion. It is also our un derstanding that the measurement is to be taken beginning at the moment before the service brake is released. Sections S5.2(e) and S5.3(b) both describe the test procedure as follows; (step numbers are added for clarity)

NHTSA procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Move the shift mechanism to the "park" position Step 5. Apply the service brake Step 6. Release the parking brake Step 7. Release the service brake Step 8. Verify that the vehicle movement was less than or equal to 150 mm.

As written, step 2 of this procedure requires application of the service brake and step 5 requires the same. But there is no action to release the service brake. We believe the intention of the procedure either requires a release of the service brake b etween steps 2 and 5, or step 5 should be eliminated (meaning the service brake is only released to begin the measurement).

Therefore, we are proposing the following revised procedure;

Toyota's Proposed Procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Release the service brake Step 5. Move the shift mechanism to the "park" position Step 6. Apply the service brake Step 7. Release the parking brake Step 8. Release the service brake Step 9. Verify that the vehicle movement was less than or equal to 150 mm

Obviously, if the vehicle is not equipped with a parking brake, Steps 4, 6, and 7 of Toyota's procedure (or Steps 5 and 6 of NHTSA's procedure) would be eliminated.

Therefore, we request an interpretation of whether Toyota's proposed procedure fulfills the intention of NHTSA's test requirement.

Should you have any further questions, please contact Mr. Chris Tinto of my staff at (202) 775-1707.

ID: nht92-3.28

DATE: 10/05/92

FROM: ROBERT F. GAYER -- EQUIPMENT COORDINATOR, TRANSPORTATION SERVICES, SALT RIVER PROJECT

TO: CHIEF COUNSEL -- NHTSA

COPYEE: TOM LANGENFELD -- GREAT DANE TRAILER

ATTACHMT: ATTACHED TO LETTER DATED 12-14-92 FROM PAUL J. RICE TO ROBERT F. GAYER (A40; STD. 121)

TEXT: Salt River Project, Transportation Services requests an interpretation of FMVSS 121 in regard to compliance of the brake systems on four (4) semi-trailers owned and operated on public streets and highways by Salt River Project. The manufacturer of the four trailers, Great Dane Trailer of Savannah Georgia has stated to Salt River Project that these trailers do not need to comply with "121", because they are "Heavy Haul Trailers". Salt River Project does not agree with Great Dane Trailer, and thus the request for the interpretation. All four (4) trailers are as follows:

Semi Trailer, flatbed, extendable - 40 feet to 65 feet.

GVWR - 68,000 lb.

Length - 45 to 65 feet

Width - 96 inches

Deck Height - 59 inches

Overall Height - 119 inches at Headboard

Axles - 20,000 lb. Rockwell, two (2) each

Service Brakes - Full Air, S-cam, with one Bendix No.

RE-6 Relay Emergency Valve only.

Note: There is no trailer spring brake valve installed on these trailers, of any kind; and only one (1) air reservoir.

Parking Brakes - MGM Spring Applied, Air Released

Trailer Serial Nos: 1GRDM8025KM013401

1GRDM8027KM013402

1GRDM8029KM013403

1GRDM8020KM013404

Attached is a copy of the SRP Vehicle Data Record for one of the trailers, and a "line set" sheet supplied by Great Dane Trailer for one of the trailers.

These four trailers are identically equipped.

Specifically, SRP is concerned that these trailers do not comply with the law, and leaves SRP open to litigation should an accident and resulting lawsuit arise, because of noncompliance in the area of S5.2.1.1 that trailers must have a reservoir that "is capable, when pressurized to 90 p.s.i., of releasing the vehicle's parking brakes at least once and that is unaffected by loss of air pressure in the service brake system"; and S5.2.1.5 that states "be protected against loss of air pressure due to failure or leakage in the system between the service reservoir and its source of air pressure by check valves or equivalent devices". We are aware of Docket 90-3 Notice 2 (corrected to Notice 3 by Notice 4) which revises a portion of FMVSS 121, but do not know the affect it will have on our concerns.

Attachments: SRP Vehicle Data Record

Great Dane Line Set Sheet (TEXT AND PHOTOS OMITTED)

ID: 1984-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 10/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Rodger I. Bloch, Sales & Marketing Director, Scott Air, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Rodger I. Bloch Sales & Marketing Director Lavelle Road, P.O. Box 1745 Alamogordo, NM 88310

Dear Mr. Block:

This responds to your letter of August 15, 1984, concerning the application of Standard No. 301, Fuel System Integrity, to an air conditioning system you supply to school bus manufacturers. You explained that your system taps into the fuel system of the school bus. If your system is installed by a manufacturer as an item of original equipment on a school bus, the manufacturer of the bus, is required by Part 567, Certification, to certify that the vehicle with the auxiliary air conditioner complies with all applicable standards, including Standard No. 301.

If you are installing the air conditioners on the vehicle before its sale to its first purchaser for purposes other than resale, then you would be considered a vehicle alterer and under Part 567.7 be required to certify that the vehicle as altered complies with all applicable standards.

In addition, you, in effect, asked about how a manufacturer or alterer demonstrates that it has exercised due care in making its certification of compliance. The agency has recently written Blue Bird Body Co. concerning this issue and I am enclosing a copy of that letter.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

August 15, 1984

Dear Mr. Burndt:

Scott Air is a manufacturer of bus air comfort systems (air conditioning). It has been called to our attention by a manufacturer of school buses, that FMVSS 301-75 relating to fuel integrity was a concern to them. They have taken all steps to certify compliance to this standard. We are now supplying a self contained air conditioning system that is skirt mounted on the drivers side.

Our system is mounted to the chasis of the vehicle and incased in a steel housing, it is protected also by the steel brackets, by which it is mounted, as well as, the vehicle itself. Please see the enclosed photo's. We are tapping into the original certified fuel system of the vehicle and our system holds only about 6.5 ounces of fuel.

I have been talking to Mr. Taylor Vincent of your staff and also Mr. Tom Grubbs with the engineering department. They have both indicated we should be able to secure a DO CARE certification. Would you or your staff be so kind as to issue instructions to me, so I can proceed in this matter.

Your assistance in this matter is greatly appreciated.

Sincerely, Rodger I. Bloch Sales & Marketing Director ds Enclosure: omitted.

ID: 1985-02.1

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Jim Preisler -- Senior Vice President, Drag Specialties

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Jim Preisler Senior Vice President Drag Specialties P.O. Box 9336 Minneapolis, MN 55440

This responds to your letter of January 17, 1985, concerning Standard No. 205, Glazing Materials. Your company manufactures an aftermarket replacement motorcycle windscreen, which incorporates auxiliary wind deflectors. Standard No. 205 specifies that the upper portion of the windshield can be made out of item 1, 6, 10, or 11 glazing materials. The glazing used in the auxiliary wind deflectors can be made out of item 1, 2, 4, 10, or 11A glazing materials. You said that the glazing material used in the windscreen and deflector meets the requirements for both item 4 and 6 glazing materials. You asked whether you can mark both those components as item 4/6 glazing materials. The answer is that you can mark them as item 4/6 materials.

Section S6 of the standard sets out the certification and marking requirements for each item of glazing material. It provides that each piece of glazing material shall be marked, in accordance with section 6 of American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways" Z-26.1 - 1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980, with a number signifying that it meets the performance requirement set for that particular glazing item number. In your case, the glazing material meets all for the requirements set for two separate item numbers. Since your product conforms to the requirements for both items 4 and 6 the agency has no objection to marking the components with both item numbers.

Sincerely,

Jeffrey R. Miller Chief Counsel

National Highway Traffic Safety Administration Room 5219 400 7th St. S.W. Washington, D.C. 20590 Mr. Frank Berndt, Chief of Council January 17, 1985

Dear Mr. Berndt:

I was referred to your office by Mr. Steven Oesch for assistance with my request.

My company is manufacturing an aftermarket replacement motorcycle windscreen. We applied for and were assigned manufacturer's code number 353, as specified in FMVSS No. 205. The material of the windscreen must meet Item #6 of the American National Standard Z26.1 1983. Our windscreen incorporates auxiliary wind deflectors (2) as part of its design. The deflector material must meet Item #4 of the same standard.

The material we are specifying for the windscreen and the deflectors meets both Items #4 and #6. I am requesting permission to mark both devices as 4/6. The reason for my request is based on cost savings. Each hot stamp die to mark the devices can be $500 to $1000 each.

Please advise me as soon as possible as our production date is closing in on us.

Sincerely,

Jim Preisler Senior Vice President

ID: nht87-1.61

TYPE: INTERPRETATION-NHTSA

DATE: 04/10/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hiromi Hori

TITLE: FMVSS INTERPRETATION

TEXT:

APR 10, 1987

AIR MAIL

Mr. Hiromi Hori Manager, Certification Regulations Section Technical Department Ichikoh Industries, Ltd. 80 Itado, Isehara-City Kanagawa Pref. 259-11 Japan

Dear Mr. Hori:

This is in reply to your letter of January 12, 1987, with reference to a lamp that is used as both an identification lamp, and as a clearance lamp. Currently the lamp projects its amber beam forward as much of the remainder of the lens is painted black. You have asked if it is permissible to remove the black paint, as a result of which the lamp will emit light in other directions.

Standard No. 108 does not prohibit removal of the black paint. The lamp, of course, must meet the photometric requirements for a clearance lamp, or for an identification lamp if it is used as part of the three lamp array. We call your attention to paragr aph 3.4 of SAE Standards J592e, July 1972, incorporated by reference in Standard No. 108. It states that "The H-V axis of a clearance or identification lamp shall be taken as parallel to the longitudinal axis of the vehicle." The lamp depicted in your s ketch appears to conflict with this requirement. Further, if the lamp is mounted as shown in the sketch, it would appear that no light will be visible, except in that half of the pattern on the lens side of the lamp base.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erica Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW. Washington D.C. 20590 U.S.A.

L62/01 January 12, 1987

Subject: Front identification lamp and front clearance lamp.

Dear Ms. Jones,

We would like to inquire about the front identification lamp and front clearance lamp.

The color of illumination from the above lamps is amber. which is stipulated in the FMVSS 108. table I "Required Motor Vehicle Lighting Equipment".

Our devices are designed to illuminate amber light to the forward only as shown in the following page.

SECTION A-A

The back side of the lens is black painted as shade to prevent the illumination to the rearward.

Question:

Is it permissible to remove the black paint from the lens? (In this case, amber light is emitted to the rearward, too.)

We appreciate your effort in responding to our inquiry.

Best regards,

Hiromi Hori, manager Certifications Regulations Section Technical Department

CC.: Mr. F. Takata. manager of representative office in Washington

ID: nht87-1.88

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Cameron-Nott

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Peter Cameron-Nott 90 Horace St: Stratford, CT 06497

This replies to your March 31, 1987 letter asking for a clarification of my January 16 letter to you regarding the importation of rebodied automobiles.

Specifically, you asked which Form HS-7 declaration is proper upon entry of a vehicle incorporating a 1966 chassis, upon which is mounted a new body whose individual equipment items meet current Federal motor vehicle safety standards applicable to them ( i.e. glazing, tires, brake hoses, lighting equipment, seat belts). The Customs officials you have contacted are unsure whether entry should be made under Box 1 or Box 3 of Form HS-7.

As we advised you earlier, a rebodied vehicle retaining its original chassis components, title, and identification number is considered to retain its original model year designation, even with a new body installed on it. Therefore, your vehicle would be considered a 1966 model. Accordingly, Box 1 would be the proper declaration: that the vehicle was manufactured on a date when no applicable safety standards were in effect. Box 3 is clearly inappropriate as there is no legal requirement for such a vehicl e to be brought into conformity with Federal safety standards. Should conformance of the individual equipment items be questioned - unlikely in our opinion -Box 2 would appear to be the appropriate declaration for these items: that they conform to all ap plicable standards and bear the manufacturer's certification to that effect (the DOT symbol on these items).

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Z. Jones Chief Counsel NHTSA 400 Seventh Street. S.W. Washington, D.C. 20590

Dear Ms. Jones:

Thank you for your letter dated January 16th concerning my questions regarding rebodied cars(copy Enclosed). I do however have a point which requires clarification.

The car is a rebodied 1966 vehicle as per paragraph #1 however the windshield, tires, brake hoses, head lights and seat belts have been replaced and have the appropriate D.O.T. FMVSS markings on them as well as paid receipts for these items.

I have asked U.S. Customs in N.Y. how I should make the customs entry on form HS-7. They have suggested that I write to you for clarification because a pre 1968 car normally is entered under section #1 however because of these equipment changes they cann ot tell me whether I should file under section #1 or section #3.

In order to avoid delays and confusion upon arrival at customs I should be grateful if you would advise me under which section D.O.T. requires the entry to be made.

Your early reply would be greatly appreciated.

Sincerely,

Peter Cameron-Nott

See 1/16/87 letter from Erika Z. Jones to Peter Cameron-Nott

ID: nht76-1.29

DATE: 12/01/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 1, 1976, letter to Mark Schwimmer of my staff, concerning the marking "V1" on passenger car tires.

The marking "V1" is not required by any Federal statute, motor vehicle safety standard, or other regulation to appear on the sidewall of passenger car tires. Furthermore, Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, 15 U.S.C. 1392(d), provides in pertinent part:

Whenever a Federal motor vehicle safety standard establshed under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.

This provision, considered with Federal Motor Vehicle Safety Standard No. 109, prohibits any State from imposing any safety labeling requirements for passenger car tires other than those contained in that standard. Any differing safety labeling requirements, including the "V1" that you have mentioned, are thus preempted and void.

SINCERELY,

NOVEMBER 1, 1976

Mark Schwimmer N.H.T.S.A. Office of Chief Counsel

The marking V1 on passenger car tires, as you know, signifies compliance to the "minimum performance requirements and uniform test procedures for new tires for passenger cars and station wagons" issued by the Vehicle Equipment Safety Commission on May 14, 1965 and later revised on October 11, 1965 and September 17, 1966.

To my knowledge no further revisions have been made, because the FMVSS 109 went into effect as of January 1, 1968. I assume, therefore, that the marking V1 should be applied only on the tires listed in the tables 1 - 6 of the regulation as follows: Table 1 - Domestic bias tires of the following series: Low Section (ex. 6.50-14) 4 & 8 P.R.

Super Balloon (ex. 6.70-15) 4 & 8 P.R.

Super Low Section (ex. 6.95-14) 4 & 8 P.R.

Table 2 - 70 Series, alpha numeric bias construction (ex. E 70-14) Table 3 - Domestic radial millimetric series from cross section Table 4 - European bias tires of the following series: Table 5 - European bias tires of the millimetric series (ex.

Table 6 - European radial tires of the millimetric series up to the cross section 155 (ex. 145 R 13) version A (32 psi)

I would like to know if the above is correct and therefore the marking V1 is no longer requested on the tires not included in this list.

If the requirements do not apply to every state in the United States, please notify me.

Thank you in advance for your reply on this matter.

PIRELLI TIRE CORPORATION

Galileo Buzzi-Ferraris Technical Manager

ID: 86-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: William Shapiro -- Manager, Regulatory Affairs, Volvo Cars of North America

TITLE: FMVSS INTERPRETATION

TEXT:

William Shapiro, P.E. Manager, Regulatory Affairs Volvo Cars of North American Rockleigh, NJ 07647 Dear Mr. Shapiro: Thank you for your letter of November 14, 1985, requesting an interpretation of Standard No. 210, Seat Belt Assembly Anchorages. You explained that Volvo is planning to voluntarily add an extra anchorage for type 2 safety belt in the middle rear designated seating position, which is already equipped with two anchorages for a Type 1 safety belt. You asked whether the third anchorage point would have to meet the anchorage location requirements set forth in S4.3.2 of the standard. As explained below, the additional anchorage would not have to comply with the location requirements of the standard. As you correctly pointed out, S4.1.2 allows manufacturers the option of installing anchorages for either a Type1 or Type 2 safety belt at the center rear designated seating position. Thus, by providing anchorages for a Type 1 belt at that seating position. Thus, by providing anchorages for a Type 1 belt at that seating position, Volvo has met the installation requirement of S4.1.2 The agency has stated in past interpretations, such as in a March 1, 1979 letter to Ford, that systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems to comply with the standards. Thus, you may install a third anchorage if it does not affect the ability of the required anchorages to meet the standard. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

11/14/85

Re: Request for Interpretation Std. 210 Seat Belt Assembly Anchorages

Dear Ms. Erika Jones:

FMVSS #210 specifies that seat belt anchorages for Type 2 seat belt assembly shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles, The standard goes on to require that seat belt anchorages for a Type 1 or a Type 2 seat belt assembly shall be installed for each designated seating position, except a passenger seat in a bus, or a designated seating position for which seat belt anchorages for Type 2 seat belt assembly are required by S 4.1.1.

Volvo is planning to voluntarily add an extra anchorage for a Type 2 seat belt in the middle rear designated seating position. This is in addition to the two (2) anchorage points for a Type 1 seat belt that are used to meet the requirements of S.4.1.2.

We interpret that this voluntary third anchorage point does not have to meet the requirements in S.4.3.2 Location. Please confirm this interpretation as soon as possible.

If additional information is required on this matter, don't hesitate to contact me.

Sincerely,

William Shapiro, P.E. Manager, Regulator Affairs Product Planning and Development Volvo Cars of North America

ID: 86-2.47

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Department Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada;

This is in response to your letter of February 5, 1986, asking for an opinion regarding a "decorative extra lighting device." It appears from the drawing that you enclosed that the device would be a part of a three-compartment housing incorporating also a rear turn signal lamp, and one that performs that tail and stop functions. It would be mounted on the rear side of a motorcycle. You have informed us that the lens color of the device would be red and its maximum luminous intensity lower than the minimum of the adjacent taillamp.

Paragraph S4.1.3 of Federal Motor Vehicle Safety Standard No. 108 forbids the installation of lighting devices not required by the standard if such a device would impair the effectiveness of the equipment that is required. It is our impression that your device performs the function of a rear side marker lamp, required to be installed on all motor vehicles other than motorcycles. However, you have not told us any of the operational characteristics of the lamp, such as whether it would be steady burning in use and activated simultaneously with the headlamp and taillamp, or whether it would flash with the rear turn signal lamp. Nevertheless, it would appear to be acceptable as a supplemental taillamp or turn signal lamp, or as a side marker lamp, either with or without the decorative trim.

Sincerely,

Erika Z. Jones Chief Counsel February 5, 1986

Att.: Ms. Erika Z. Jones Chief Counsel

Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U. S. A.

Re. : Installation of decorative extra lighting device to the vehicle, which is not specified in FMVSS No. 108

Dear Ms. Jones,

According to your letter of Nov. 4, 1985, we would ask you an advice for the following decorative extra lighting device.

This device will be mounted on the rear side of a motorcycle. We enclose a drawing which shows the size, shape and the proximity to a tail & stop lamp and a rear turn signal lamp. A lens color of this decorative extra lamp is red and its maximum luminous intensity is lower than the minimum of the tail lamp. There is a possibility of attaching an ornament on this accessory lamp.

We are looking forward to your advice.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada, Manager, Automotive Lighting Engineering Control Dept.

Enc. The details of the device