Interpretation ID: nht90-3.81

TYPE: Interpretation-NHTSA

DATE: September 4, 1990

FROM: Hiroshi Kato -- Vice President, Mitsubishi Motors America, Inc.

TO: Jack Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to drawing of proposed illumination on rear panel garnish and photo of 1988 Pontiac Fiero (graphics omitted); Also attached to letter dated 9-26-90 from P.J. Rice to H. Kato (A36; Std. 108)

TEXT:

This letter serves to request an interpretation of FMVSS 108, Lights and Relectors. S.5.1.3 of Standard 108 states that "no additional lamp, reflective device, or other motor vehicle equipment shall be installed that impairs the effectiveness of lightin g equipment required by this standard."

We are considering lighting the rear panel garnish of a vehicle to illuminate the word "MITSUBISHI" at 0.1 cd (0.02 cd/in) when the vehicle headlamp system is turned on. This illumination would not be lighting required by FMVSS 108. The enclosed page s hows the proposed illumination and specifications. A similar illumination on the 1988 model year Pontiac Fiero is also shown.

We would like your determination as to whether the illumination described above would be considered impairment of the effectiveness of required lighting as described in S.5.1.3.

If the described illumination is considered an impairment due to the candela power, we would like to know what candela would be acceptable.

Also, we would like to confirm that if the center of the rear panel garnish was illuminated as a supplemental tail lamp and the word "MITSUBISHI" was not illuminated, this type of lighting would be allowed under FMVSS 108.

Your prompt response would be appreciated.

Enclosure

Drawing of proposed illumination on rear panel garnish and photo of 1988 Pontiac Fiero (graphics omitted).