Mr. Charles I. Sassoon
125 Cabot Ct.
Hauppauge, NY 11788
Re: Maxxima Lamp M40130R
Dear Mr. Sassoon:
This is in reply to your letter to Taylor Vinson of this Office. You asked for our opinion whether Federal Motor Vehicle Safety Standard No. 108 permits the "Maxxima LED Sequential Stop/Tail/Turn Signal Lamp M40130R" that your company seeks to manufacture. You did not state whether the Maxxima lamp is intended as original equipment or as replacement equipment.
According to your letter, "when turn signaling is activated, separate sections of light are illuminated sequentially." The stop and tail functions "operate as normal steady burn and intermittent braking respectively." You have enclosed a test report by an independent laboratory indicating that a sample Maxxima lamp met all photometric requirements for the three functions of the lamp. You have also provided a sample of the Maxxima lamp. The Maxxima lamp is circular in shape, and when we activated it, we found that "sequentially" meant that the turn signal function illuminated from the center outwards to the perimeter. However, we found that the stop function also activated identically; the lamp became illuminated in two distinct phases.
Paragraph S5.1.4, Equipment combinations, of Standard No. 108 states that "two or more lamps . . . may be combined if the requirements for each lamp . . . are met," with exceptions not relevant here. Therefore, Standard No. 108 does not prohibit a single lamp that combines complying stop, tail, and turn signal functions. Essential to compliance is conformance to the specifications of SAE standards incorporated by reference in Standard No. 108 as well as specific requirements of Standard No. 108 itself. Because the Maxxima lamp may be used on any four-wheeled motor vehicle regardless of width, its stop lamp function must comply with both SAE J1398 MAY85 and SAE J586 MAY84. The Maxxima turn signal lamp function must comply with both SAE J1395 APR85 and SAE J588 NOV84. The taillamp function must comply with SAE J585e, September 1977, which applies to all vehicles regardless of width.
I enclose a copy of our response to W.E. Baldwin, PhD., who wrote us on September 1, 1988, concerning a sequentially-activated center high-mounted stop lamp. We informed Dr. Baldwin that Standard No. 108 requires stop lamps to be activated upon application of the service brakes, and that this meant that all bulbs providing the center stop signal must be simultaneously activated, not sequentially. Similarly, all light sources providing a turn signal must be illuminated simultaneously when the turn signal operating control is activated. Failure of all light sources to illuminate simultaneously means that the stop and turn signal functions of the Maxxima lamp would not comply with the minimum luminous lens area requirement of applicable SAE standards at all times after the brake pedal is applied or the turn signal operating control is activated. Thus, the stop and turn signal function of the Maxxima lamp would not comply with Standard No. 108.
Standard No. 108 also requires a minimal size for the functional lighted lens area of a turn signal lamp. The Maxxima turn signal lamp function must comply with SAE J1395 APR85, paragraph 5.3.2 of which specifies that the area be at least 75 square centimeters for turn signal lamps on vehicles whose overall width is 80 inches or more. Paragraph S184.108.40.206(a) of Standard No. 108 specifies that this area be at least 50 square centimeters for narrower vehicles. When the turn signal function is activated on the Maxxima lamp, the minimum area requirement is not met at the time the first cycle begins because of the sequential nature of the lamp’s operation, a further noncompliance with Standard No. 108.
If you have further questions, you may call Taylor Vinson of this Office (202-366-5263).