Interpretation ID: nht78-2.21
DATE: 07/19/78
FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA
TO: Lighting and Optic Laboratory
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter of May 8, 1978, to Mr. Vinson of this office concerning the version of SAE J567, Bulb Sockets, applicable as a subreferenced standard to Federal Motor Vehicle Safety Standard No. 108.
The SAE standards which are specified in Standard No. 108 are cited by a number and letter to indicate the applicable version. These directly referenced SAE standards often subreference other SAE standards by inclusion of such terms as "reference is made to SAE J " or "reference SAE J " in which case, unless otherwise specified in Standard No. 108, the subreferenced standard is the version contained in the 1970 SAE Handbook (See paragraph S5.1 of Standard No. 108).
The subreferenced SAE standard closest in subject matter to J567 is J573d, "Lamp Bulbs and Sealed Units", December 1968. By NHTSA interpretation J573 is not exclusive, and other bulb designs including tubular type bulbs are permitted which are not included in SAE J573. There is no subreferenced notation to SAE J567 contained in SAE J573d. Further, although the agency issued an interpretation in 1968 indicating that SAE Standard J575d, Tests for Motor Vehicle Lighting Devices and Components, August 1967, referenced J567, that statement was incorrect and J575d contains no such reference. Therefore SAE J567 is not a subreferenced standard in Standard No. 108. When an SAE Standard is not referenced or subreferenced by a Federal Standard, compliance with it is voluntary, and you may therefore use (or not use) SAE J567 or any version thereof as you choose, as long as the assembled lamp complies with Standard No. 108.
SINCERELY,
FIAT SETTORE AUTOMOBILE
8th May, 1978
TAYLOR VINSON Office of Chief Counsel National Highway Traffic Safety Administration
FMVSS N. 108 - Lamps, Reflective devices and Associated equipment.
Dear Mr. Vinson,
on behalf of Italian Electrotechnical Committee (CEI) I pose to you a question regarding SAE Standard related to bulb and socket.
The International Electrotechnical Commission (IEC) issued a number of Standard sheets applicable to bulb base, socket, and lampholders for automotive use.
The Italian Committee made a reserve with explication that IEC dimension and tolerances are not compatibles with ones stated in SAE Standard J 567b.
In many cases the lighting devices for motor cars are the same for European market and for North-American market. Car manufacturers and lamp manufacturers obviously wishes to use only one type of lampholder, for internal standardization, cost reduction.
The IEC/Technical Committee 34 (Lamp and holder) affirmed that SAE J 567 b is not longer applicable because she is obsolete, replaced by J 567 c and the applicable SAE Standard for lighting equipment reported only the reference to "SAE Standard J 567" without any indication of edition.
Finally, the Chairman of IEC/TC 34, Mr. E.M. Kooker (G.E. - Lamp Division) suggested us to present the question directly to NHTSA.
The questions are the following:
"In the case of SAE Standard J 567, which is the edition applicable: the J 567 b, current at first publication of Standard 108 (1966), or the new one, J 567 c (1970)?
If either "b" or "c" are applicable, and the lamp manufacturer chose the "c" edition, how he can demonstrate the compliance with the Standard?
Should he declare that the lampholder would be checked with the gages of tables 1 and 2 in J 567 c and not with a caliper or other instrument?".
We think that your explanation will be very useful in our daily work for motor vehicle safety.
(G. Bertella) Chief, Lighting and Optic Laboratory