Interpretation ID: nht71-4.35

DATE: 10/29/71

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Joseph Lucas (Electrical), Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the petition of Joseph Lucas (Electrical) Ltd. dated October 13, 1971, for rulemaking to amend Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Specifically, you have asked for an amendment of paragraph S4.1.2 either to reduce the(Illegible Word) test cycle of the warpage test for backup and stop lamps from 10 minutes to 5 minutes, or to conduct the test for these lamps using a continuously flashing filament.

Petitions for reconsideration of the 10 minute heat test cycle were filed following amendment of Standard No. 108 on October 31, 1970 (35 F.R. 16840). These petitions were denied on February 3, 1971 (36 F.R. 1896), because the Traffic Safety Administration had determined that the 10-minute cycle is appropriate in view of the frequency of usage of stop and backup lamps. I enclose a copy of the denial.

The Administrator has determined that your petition contains no new information such as to merit rulemaking on this issue, and we must therefore respectfully deny your petition.