Interpretation ID: nht92-1.2

DATE: December 30, 1992

FROM: Stephen P. Wood -- Assistant Chief Counsel for Rulemaking, NHTSA; Signature by John Womack

TO: Rodney T. Nash -- Vice President Engineering, Collins Industries, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/9/92 from Rodney T. Nash to Administrator, NHTSA (OCC 7996)

TEXT:

This responds to your letter to the Administrator, National Highway Traffic Safety Administration (NHTSA), received in this office on November 18, 1992, and your telephone conversation of November 30, 1992 with Walter Myers of this office, regarding the proper classification of an ambulance.

You indicated that Wheeled Coach Industries of Orlando, Florida, a subsidiary of Collins Industries, produces ambulances that are built on truck chassis. You stated that in the past those vehicles have been classified as trucks, but that Ford Motor Company auditors told you that they should be classified as multipurpose passenger vehicles (MPV). You said that you needed to know how v m;swl4(FAA@P/O=1[[YCBX[YX\\\YHH]Y[ H\YX] [XTBBH \Y\Y[X[[\H][ \\H\[\Z X\B X\HY[Y [ HHY\[Y[] [ H MK\H[BZ XH] [ ]H\^\HZ[\\YY\H L\B\ X \XYZ] \HX\\] XX[X]\\B\[[\Y\] [ated into Standard No. 108, any device that contains more than three lighted sections, or LEDs, need only comply with the requirements prescribed for three lighted sections.

"(2) Where the above view is acceptable, could we consider the number of lighted section (sic) as 'one' in case of a lamp which contains three LED arrays arranged as shown in the attached drawing, if the circumferenc (sic) of three projected luminous areas does not exceed 150mm both in horizontal and vertical dimension?"

The answer is no under Standard No. 108 as it presently exists. The drawing you have enclosed depicts three "lighted areas of LEDs" with two separations. Your question is based upon SAE J1889, which defines a "one compartment LED lamp" as one whose "maximum projected linear dimension" does not exceed 150mm. Thus, the linear dimension of a two-compartment LED lamp is 151-300mm, and that of a three-compartment LED lamp is 301mm and greater. These dimensional specifications prevent LED lamps from achietion of persons. Accordingly, an ambulance falls within the definition of MPV rather than truck.

I hope this will help clarify this issue for you. Should you have any further questions in this regard, please feel free to contact Mr. Myers at this address or at (202) 366-2992.