ID: 11698.ZTV

M. Guy Dorleans
International Regulatory Affairs Manager
VALEO
34, rue St.-Andre
93012 Bobigny cedex
France

Dear M. Dorleans:

We have received your letter of March 19, 1996, asking for an interpretation of paragraphs S7.2(a) and S7.5(g) of Motor Vehicle Safety Standard No. 108. These paragraphs require that lenses of replaceable bulb headlamps be marked with the DOT symbol and the HB-type of light source used in the headlamp. Your engineers contemplate a clear-lensed headlamp, and would like to engrave these markings on a visible area of the inner bezel where they are easily seen from the outside. You ask for confirmation that this would meet the "spirit" of the requirement even if the definition of lens doesn't apply to an interior part.

The Federal motor vehicle safety standards specify objective requirements. Failure to mark the lens in the manner specified by Standard No. 108 would create a noncompliance with the standard. Paragraphs S7.2(a) and S7.5(g) are very specific in their requirements that the lens be marked, and do not allow alternative marking of the bezel if the lens is clear.

If you have any questions, you may refer them to Taylor Vinson of this Office (FAX 202-366-3820).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:4/25/96

ID: 19844.ztv

Mr. Glenn Panes
921 Todville Road
Seabrook, TX 77586

Dear Mr. Panes:

This is in reply to your e-mail of April 7, 1999.

You are interested in buying an aftermarket combination stop/turn signal lamp which has a clear lens and red and amber bulbs. You ask whether the lamps are legal to use. Apparently your local police do not object, but you are concerned about being stopped somewhere else.

The answer to your question depends on a number of factual issues, as well as the laws of local and state jurisdictions. Therefore, this is not a question we can fully answer for you.

We establish the Federal motor vehicle safety standards that apply to new motor vehicles and vehicle equipment from the time of manufacture until time of first sale. One of these, Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment specifies the lighting equipment a vehicle must have when manufactured, and the performance of this original equipment and the aftermarket equipment intended to replace it. We can tell you how this standard relates to the aftermarket lamp you describe.

Aftermarket replacement equipment is required to comply with Federal new-equipment requirements, and be certified as complying. We are unable to tell whether the combination stop/turn signal lamp you describe complies but would like to make a few comments on it. Under Standard No. 108, a turn signal lamp is permitted to emit amber light. The amber light may be provided by either an amber lens and clear bulb, or an amber bulb and a clear lens. The question, then, is whether the turn signal lamp meets Standard No. 108's photometric specifications.

Standard No. 108 has incorporated by reference the Society of Automotive Engineers (SAE) specifications for amber turn signal lamps.

SAE specifications for stop lamps are also incorporated by reference in Standard No. 108. These specifications require the use of special bulbs for testing purposes. However, SAE has no specifications for red bulbs. Thus, it may not be possible for manufacturers to certify that a lamp meets all applicable Federal motor vehicle safety standards. Nevertheless, if the manufacturer has marked the replacement lamp with a "DOT" symbol (or certified its conformance on its container), you may regard that as its representation that the lamp meets all applicable Federal requirements.

This certification, however, does not mean that the original equipment lamp can be removed and the new, different one substituted without causing a noncompliance with Standard No. 108. The standard requires vehicles to have two red reflex reflectors on their rear, and one on each side at the rear. In many instances, these reflectors are incorporated into red rear combination lamp lenses. Thus, depending on the location of red reflex reflectors on the side and rear of the car, substitution of a white-lensed stop lamp might remove this desirable safety feature.

Even if the lamp were certified as complying, if installation of the lamp you are interested in would result in removal of the only reflex reflectors on the side and/or rear, there would be a violation of Federal law if this work was performed by a manufacturer, distributor, dealer, or motor vehicle repair business, and if the modifier did not add two reflex reflectors to the rear of the car. However, this prohibition does not apply to you, if you, the vehicle's owner, substitutes the lamp. Nevertheless, it is possible that you could be cited somewhere for a violation of local laws if the vehicle lacks rear reflex reflectors. As a general rule, we urge caution in replacing any lighting equipment with novelty items.

Some new motor vehicles may be equipped with original equipment rear combination lamps that have clear lenses, but the red color of the light emanating from these lamps is produced by a clear bulb projecting through a red inner plastic lens. Such lamps do not use red bulbs and are certified as complying.

If you have any further questions, you can contact Taylor Vinson of this Office, either by phone (202-366-5263), or by e-mail (Tvinson@nhtsa.dot.gov).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/14/99

ID: 11552ZTV

M. Guy Dorleans
International Regulatory Affairs Manager
Valeo
34, rue Saint-AndrJ
93012 Bobigny
France

Dear M. Dorleans:

We have received your letter of January 31, 1996, asking for confirmation that certain motor vehicle equipment being manufactured by Valeo is considered a replaceable headlamp lens for purposes of Motor Vehicle Safety Standard No. 108. You have enclosed drawings to assist us in this interpretation.

The drawings show that the "replaceable lens" as you term it is a bonded assembly of an opaque device and a translucent device. The translucent device seems intended to be placed in front of two unidentified light sources (we assume that at least one of these provides headlighting). The opaque device serves as the spacer to locate the translucent device as just stated. We confirm that this equipment is a "replaceable lens" within the meaning of Standard No. 108 even though it does contain opaque material.

You have stated that the markings required by S7.2(e) (for a replacement headlamp lens with seal are "placed on the upper flange of the opaque part." In this position, it appears that the markings will not be visible when the headlamp is installed. Paragraph S7.2(a) requires that the lens of each replacement equipment headlamp be marked with the symbol "DOT" which constitutes the manufacturer's certification of compliance with all applicable standards. For purposes of complying with S7.2(a), and to reassure the public of the

compliance of the headlamp, we urge that Valeo ensure that the DOT marking is applied to the front of the lens where it will be visible to an observer after it has been installed.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:3/14/96

ID: 19023.ztv

Herr Olaf Schmidt
Manager, R &D
Hella K.G. Hueck & Co.
Rixbecker Str. 75
59552 Lippstadt
Germany

Dear Herr Schmidt:

We apologize for the delay in answering your letter of March 27, 1998, on headlamp labels, but this Office did not receive a copy of it until November 3. If you wish to communicate with us by fax, we recommend that you mail a hard copy at the same time to minimize the possibility of lost correspondence.

You report that "modern headlamp designs have the approval markings for the USA as well as for the European market on the lens as it is required by the relevant laws." In order to minimize confusion as to whether a headlamp has been designed to conform to Federal Motor Vehicle Safety Standard No. 108, or to conform with ECE requirements, Hella would like to place the words "Not D.O.T. approved" or "Not D.O.T. certified" on the bottom line of the labels that the company places on the rear of the headlamp housing of ECE headlamps. You have asked that we agree with your plan.

We cannot agree with your plan. We understand that, under this plan, the "DOT" symbol would appear on each lens. S7.2(a) of Standard No. 108 requires that the lens of each original and replacement headlamp manufactured for sale in the United States must be marked with the symbol "DOT." This symbol is the certification required by 49 U.S.C. 30115 that the headlamp meets Standard No. 108. It cannot be qualified by a disclaimer placed on a label on the rear of the headlamp housing. A manufacturer must not mark a headlamp lens with the DOT symbol if the headlamp does not comply with Standard No. 108.

A manufacturer who applies the DOT symbol to the lens of a headlamp that meets ECE requirements but does not comply with Standard No. 108, in our view, has provided certification that is materially false and misleading, and the manufacturer may be liable for a civil penalty. The maximum civil penalties authorized are $1,100 for importation of a single noncomplying headlamp, and $1,100 for each instance of false and misleading certification. We may impose a penalty up to a total of $880,000 for any related series of violations.

Should it come to our attention that noncomplying headlamps with dual ECE/DOT markings are being imported into the United States, we will investigate the matter with a view towards seeking a civil penalty from any responsible headlamp manufacturer doing business in the United States. In addition, if nonconforming headlamps with dual ECE/DOT markings have previously been imported and sold, our laws require the importer to notify purchasers of the noncompliance, and to remedy the noncompliance at no charge.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108#VSA
d.2/26/99

ID: nht79-1.14

DATE: 10/04/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Grote Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT:

October 4, 1979

Mr. C. J. Newman Vice President, Engineering The Grote Manufacturing Company State Rt. 7 - P.O. Box 766 Madison, Indiana 47250

Dear Mr. Newman:

This in reply to your letter of August 23, 1979, to the former Chief Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp "meets the intent" of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.

You have quoted paragraph 3.4 of SAE Standard J588e, September 1970, which states "the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles." It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.

We would also like to observe that since the side marker signal uses the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.

Sincerely,

Frank Berndt Chief Counsel

Mr. Taylor Vinson Office of the Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATlON 400 Seventh Street S W WASHINGTON DC 20590

September 24, 1979

Dear Mr. Vinson

Request for Interpretation

In the case of a motorcycle headlamp, Table III of FMVSS 108 cites SAE J584, which in turn specifies that for photometric tests, the "bulb or unit shall be operated at its rated voltage during the test."

Where the material bulb is an H1, H2, H3 or H4 halogen bulb that bears the E-mark signifying that it is in compliance with E/ECE/TRANS/505/Rev.1/Add.36, that is to say in compliance with Regulation 37 of the Geneva Agreement of 20 March 1958 as adopted by the general European governments, is the rated voltage required by SAE J584 the same rated voltage of ECE Regulation 37?

Yours sincerely

H J T YOUNG Vice President - Technical Affairs

E/ECE/324 ) E/ECE/TRANS/505 )Rev.1/Add.36 Regulation No. 37 Annex 1 page 21/22

CATEGORY H4 Sheet H4/2

Characteristics

Lamps of normal production Standard lamps

*Insert chart here

1/ Where a yellow outer bulb is used, "m" and "n" denote the maximum dimensions of this bulb; where there is no outer bulb "m" denotes the maximum length of the lamp.

2/ It must be possible to insert the lamp into a cylinder of diameter "s" concentric with the reference axis and limited at one end by a plane parallel to and 20 mm distant from the reference plane and at the other end by a hemisphere of radius S/2.

3/ The obscuration must extend at least as far as the cylindrical part of the bulb. It must also overlap the internal shield when the latter is viewed in a direction perpendicular to the reference axis. The effect sought by obscuration may also be achieved by other means.

4/ The values indicated in the left-hand column relate to the driving beam. Those indicated in the right-hand column relate to the passing beam.

August 23, 1979

U. S. Department of Transportation NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attn: Mr. J. J. Levin, Jr. Chief Counsel

Dear Sir:

We are considering certain revisions to our line of front double-faced pedestal mount turn signal lamps. Before making any commitment to our customers or before making any tool changes, we need your opinion as to whether the lamp meets the requirements of Federal Motor Vehicle Safety Standard 108.

In the past, double-faced turn signal lamps having side marker devices have normally been manufactured with two bulbs -- a 1156 or 32 candle power bulb functioning as the turn signal system, and a 2 or 3 candle power bulb functioning as the side marker device. In this case, having an yellow lens to the front and a red lens to the rear. Our proposed change is to use one 1157 bulb, dual function 32 - 3 candle power filaments where the 32 candle power filament is used as the turn signal function and the 3 candle power is used as the side marker device. In order to do this, a yellow lens to the front, yellow lens to the rear is required and also the baffling inside of the double-faced lamp has to be reduced in order to meet the side marker requirements. With this particular design, all three lenses -- the lens to the front, to the rear and to the side -- function as part of the side marker device.

The question that we have is the intent of rulemaking covering turn signal lamps. The turn signal lamp, SA J588e, last revised September, 1970, includes Item 3.4 which states, "The flashing signal from a double-faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles."

With the baffling area reduced inside of the lamp as indicated by the sample, and since the requirements are very subjective, we need an opinion as to whether the lamp does or does not meet the intent of Federal Motor Vehicle Safety Standard 108.

Would you please review the sample and give us your opinion as soon as possible.

Yours very truly,

THE GROTE MANUFACTURING COMPANY

C. J. Newman Vise President, Engineering

CJN/aj

ID: nht76-2.26

DATE: 10/07/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 7, 1976, asking several questions concerning paragraph S4.4.1 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to respond by September 29 as you requested. Your questions and our answers are as follows:

"1. What is the DOT specific definition and interpretation of the words 'combined optically' as they appear in paragraph S4.4.1 of DOT 108?"

In pertinent part, S4.4.1 states that "no clearance lamp may be combined optically with any taillamp." The phrase "combined optically" as used here means that the luminous area of a lens used for a taillamp may not be also used as the luminous area of a lens for a clearance lamp. In other words lamps are "combined optically" when the same luminous area of a lens is lighted for more than a single function.

"2. Can a clearance lamp and tail lamp be combined in a single compartment with no opaque barrier wall existing between the clearance lamp bulb and the tail lamp bulb?"

The answer is no because the same luminous area of the lens would be lighted when both lamps are in use, and the lamps would be "combined optically."

"3. Does the DOT have no objection to a flashing red signal issuing from the side (at right angles to the fore-aft center line of the trailer) of the clearance lamp?"

Generally S4.6(b) requires most vehicle lamps to be steady burning in normal operation. If the right angle lamp serves as the rear side marker lamp, however, S4.6(b) allows it to be flashed for signaling.

"4. What is the DOT specific definition and interpretation of the term 'clearance lamp' as it is used in DOT 108?"

The term "clearance lamps" is defined by SAE Standard J592e, incorporated by reference in Standard No. 108, and are "lamps which show to the front or rear of a vehicle . . . to indicate the overall width and height of the vehicle."

"5. Does the 'clearance lamp' as the words are used in DOT 108 indicate a lamp intended to serve as its major function, a back up lamp in the event of failure of the tail light filament in the combination tail, turn and stop light bulb."

There is no intent that a clearance lamp serve as a backup lamp in the event of a taillamp filament failure though obviously both lamps perform a marking function.

"6. If DOT approves the combination of a clearance lamp and tail lamp in the same compartment, would it also approve for a boat trailer, moving the tail light outboard to show the extreme width of an over 80" vehicle and eliminate the need for a clearance lamp under those circumstances."

The question is moot since a combination clearance lamp-taillamp is not permitted.

I understand that you discussed the photometric test procedure for optically combined lamps with Mr. Owen of this agency, by telephone on September 22, 1976. So that there may be no misunderstanding I would like to set forth the test procedure in this letter. If a single lamp bulb (or filament) is used in the combined lamp, the photometrics for all of the functions must be met simultaneously. If two or more lamp bulbs (or filaments) are used and each is to provide a separate function, only those which provide that function are to be energized during the photometric test. Therefore, in a multiple compartment side marker and clearance lamp (or a multiple compartment tail and clearance lamp that is not optically combined), the clearance lamp bulb is not energized during the photometric test for the other function, and vice versa.

I hope this answers your questions.

SINCERELY,

WESBAR CORPORATION

September 7, 1976

Frank Berndt Acting Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration

Refer: DOT 108, paragraph S4.4.1

On June 9, 1975 your predecessor in office answered an inquiry we made relative to a light design, and the last paragraph of his letter stated in part:

"Since the clearance lamp and tail lamp are in separate compartments and not optically combined -- the lamp design does not violate S4.4.1."

We have recently seen two lamps which bear the letters "DOT", in each of which the clearance, tail light and turn signal bulbs are all in the same compartment, i.e. the clearance lamp is not in a separate compartment.

It has always been the opinion of the writer and of boat trailer manufacturers, that in order to comply with S4.4.1, the clearance lamp would have to be in a compartment separated from the tail and stop lamp. However, while we were in Washington last week visiting your compliance office, we were advised that a Mr. Lou Owen had given a verbal interpretation of S4.4.1 in which he gave approval for the tail and clearance lamp to be in a single compartment, with no separating wall between them.

It would seem logical that tail lamp and clearance lamp should be separately compartmented. If the bulbs were in the same compartment with no shielding between them, the stop and turn light would illuminate that section of the compartment intended as a clearance lamp area, and at times the clearance lamp would appear to be flashing as well as varying in intensity. This would make for a confusing and hazardous situation for a driver traveling some distance behind a trailer equipped with such a combination lamp.

If this verbal interpretation which approves having the two lamp bulb mounted in the same compartment without a separating wall is valid, why should there be any need for a clearance lamp on a boat trailer since the tail lights could be mounted sufficiently outboard so they would indicate, when lighted, the overall width of the trailer?

We would appreciate receiving the DOT's specific interpretation of the words "combined optically". In its usual context, the words "combined optically" would mean a combination of light source and lens, and applied to S4.4.1 would seem to indicate that, in fact, the clearance lamp would have to be separately compartmented from the tail, stop, turn, and hazard lamp compartment.

When the clearance and tail lamp are housed in the same compartment there is a definite impairment of the combination turn, stop and hazard function of the lamp and an unsafe and confusing situation exists. We can report to you that while conducting an actual night test at a country road intersection, when a trailer was approaching the intersection with turn signal bulb flashing in the uncompartmented tail light, at 150 feet distance it was difficult to tell if the trailer ahead was on the same course as the following vehicle or crossing ahead of it at right angles.

While we were at the compliance section office, we were appalled to hear an interpretation of the term "clearance light" to the effect that the clearance lamp was not necessarily a separate lamp but was intended as a "back-up" light in the event the tail light filament should fail.

We have never ever heard or had it intimated to us that such was the purpose of a clearance lamp and we don't believe that it was ever intended to be so defined. When you consider the fact that the lamp on a semi trailer is at the uppermost corner of the trailer body (a long distance from the tail lamp!), and that travel trailers, buses and other vehicles also have the clearance lamp at the top extreme corners of the vehicles, it is difficult to conceive of their application as being a back up substitute for a defective tail lamp.

Carrying our argument further, on a trailer of less than 80" in width NO clearance lamp is required but the possibility of failure of the tail lamp filament is just as great. What then is supposed to serve as "back up" lamp for it? It is our observation that someone was just not thinking when he made the statement that a clearance lamp is really only there to serve as a "back up" lamp for the tail light.

In summary we ask for your specific answers to the following:

1. What is the DOT specific definition and interpretation of the words "combined optically" as they appear in paragraph S4.4.1 of DOT 108?

2. Can a clearance lamp and tail lamp be combined in a single compartment with no opaque barrier wall existing between the clearance lamp bulb and the tail lamp bulb?

3. Does the DOT have no objection to a flashing red signal issuing from the side (at right angles to the fore-aft center line of the trailer) of the clearance lamp?

4. What is the DOT specific definition and interpretation of the term "clearance lamp" as it is used in DOT 108?

5. Does the "clearance lamp" as the words are used in DOT 108 indicate a lamp intended to serve as its major function, a back up lamp in the event of failure of the tail light filament in the combination tail, turn and stop light bulb.

6. If DOT approves the combination of a clearance lamp and tail lamp in the same compartment, would it also approve for a boat trailer, moving the tail light outboard to show the extreme width of an over 80" vehicle and eliminate the need for a clearance lamp under those circumstances.

On September 29, 1976 there will be a meeting of the Trailer Manufacturers Association. In attendance will be representatives of all major manufacturers of boat trailers. We would appreciate your expediting your replies to the six questions posed above in order that we may give a copy of them to the group attending that meeting.

Since your interpretation of the questions given in this letter are of such vital importance to the boat trailer manufacturer, dealer and consumer, we would be most grateful for your clear, concise answers.

For your ready reference we attach copies of our previous correspondence and the reply we received. We also submit for your study, photos of a typical lamp where tail lamp and clearance lamp are combined in one compartment.

Looking forward to receiving your prompt response, we remain.

B. R. Weber Executive Vice President

cc: SEN. WILLIAM PROXMIRE; SEN. GAYLORD NELSON; REP. WILLIAM A. STEIGER

ID: aiam2930

Dear Mr. Ratz: This is in reply to your letter of December 8, 1978, asking whether th front and rear clearance lamps on your Model 870 Urban transit coach comply with Federal Motor Vehicle Safety Standard No. 108.; The front clearance lamps on the Model 870 are combined with the tur signal lamps, side marker lamps, and side reflex reflectors. The units are located 'on line with and just outboard of each rectangular headlamp,' with lens center 32 inches above the road surface, at a point that appears to be at the vehicle's overall width. The rear clearance lamps are combined with the stop lamps and rear side marker lamps, their horizontal center lines 64 inches above the road surface, at approximately the vehicle's overall width. Front and rear identification lamps are mounted at the top of the vehicle.; The general rule expressed by Table II of Standard No. 108 is tha clearance lamps must be mounted 'to indicate the overall width of the vehicle ... and as near the top thereof as practicable.' But a partial exception is provided by S4.3.1.4.: When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps need not meet the requirement of Table II that they be located as close as practicable to the top of the vehicle.'; This means that the mid-body location of the rear clearance lamp i acceptable since the rear identification lamps are at the extreme height of the vehicle. But the exception does not extend to the front clearance lamps. While Standard No. 108 allows the manufacturer to determine what location is 'as close as practicable to the top of the vehicle', there will be instances when the overall width of the vehicle will not be indicated by the highest location. In such instances the best location will be the one that most closely approximates the intent behind the requirement - to indicate the overall width.; Specifically with reference to the Model 870, it appears to us that th close proximity of the combination lamp to the headlamp may result in the effectiveness of the clearance lamp being impaired by the brightness of the headlamp, and that the most practicable location sufficiently indicating the overall width of the vehicle, would be at the outer edges of the body directly below the windshield.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

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: 1985-04.30

TYPE: INTERPRETATION-NHTSA

DATE: 11/18/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Finbarr J. O'Neill

TITLE: FMVSS INTERPRETATION

TEXT:

November 18, 1985 Finbarr J. O'Neill General Counsel Hyundai Motor America P.O. Box 2669 Garden Grove, California 92642-2669 Dear Mr. O'Neill: September 18, 1985, to Mr. Vinson of this office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to application of the "DOT" symbol to lighting equipment. You first ask for confirmation of your interpretation that Standard No. 108 does not require the DOT symbol on original equipment lenses of lamps other than headlamps. That is correct; the general certification of the vehicle manufacturer that its product complies with all applicable Federal motor vehicle safety standards is inclusive of all original equipment and of all requirements of the specific standards such as the color requirements for lenses imposed by Standard No. 108. You have also asked for confirmation that under Standard No. 108 the marking of replacement lenses with the DOT symbol is optional. That is correct; the other permissible certification options for replacement lenses are those imposed by 15 U.S.C. 1403, certification in the form of a label or tag on the lens itself or the container in which it is shipped. Finally, you have asked whether the National Highway Traffic Safety Administration can comment on whether it intends to propose mandatory marking of lenses in the near future. We have received a petition for rulemaking to amend Standard No. 108 to require items of replacement lighting equipment to be marked with the DOT symbol. However, the agency has not announced a decision on the petition at this time. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: nht74-1.39

DATE: 02/25/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: Ford

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 24, 1974, asking for an interpretation as to whether a rear lamp assembly design that Ford demonstrated to NHTSA representatives conforms to the location requirements of Standard No. 108. The assembly consists of three units which, from outboard to inboard, as a rear lighting assembly, comprise the tail lamp/stop lamp, backup lamp, and turn signal lamp.

Standard No. 108 specifies that stop lamps, tail lamps, and turn signal lamps be "as far apart as practicable." The standard does not specify a minimum separation distance of lamps, a maximum permissible location inboard, or location of one system relative to another. The determination of practicability in lamp spacing is to be made by the vehicle manufacturer, and the agency has generally afforded manufacturers some latitude in this interpretation.

Therefore, the configuration you have described and demonstrated would not violate Standard No. 108. It should be noted, however, that it would be in conflict with the requirements for rear turn signals and stop lamps as proposed in Docket 69-19, Notice 3.

Sincerely,

ATTACH.

January 24, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Dr. Gregory:

On January 14 Ford demonstrated a rear lamp design that it plans to use on one of its 1975 models. The purpose of the demonstration was to display the design and make sure there were no misunderstandings as to the lamp's conformance with the location requirements of Motor Vehicle Safety Standard No. 108. Ford pointed out that the various functions of the lamp were "as far apart as practicable" for the rear end design of the vehicle and for the separation of signal functions by space and color in which both the NHTSA and Ford are interested.

For the record the lamp assembly may be described as follows: Red White Amber Left side shown (Approximately to scale)

* The outboard pod has a red lens and wraps around the quarter panel, thus serving as a rear side market, taillamp and stop lamp and as side and rear reflex reflectors.

* The center pod has a white lens and serves as the backup lamp.

* The inboard pod has an amber lens and serves as the turn signal lamp.

While it is our impression that NHTSA technical personnel who examined this lamp design agreed that it fully meets the location requirements of Standard No. 108, we should appreciate formal confirmation that the Administration concurs in our interpretation.

Respectfully submitted,

J. C. Eckhold -- Director, Automotive Safety Office, FORD MOTOR COMPANY