Interpretation 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