Interpretation ID: nht90-4.64

TYPE: Interpretation-NHTSA

DATE: November 20, 1990

FROM: M. Iwase -- General Manager, Technical Administration Dept., Koito Manufacturing Co., Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re FMVSS No. 108 (Lamp, reflective devices, and associated equipment) Interpretation and/or Petition for Combination of Headlighting Systems

ATTACHMT: Attached to letter dated 12-13-90 to M. Iwase from Paul Jackson Rice (A36; Std. 108)

TEXT:

We would hereby ask you to provide us with your kind advice to the subject matter.

There are three (3) different kinds of headlighting system as specified in the current FMVSS No. 108 --- Sealed Beam Headlighting System of S7.3, Integral Beam Headlighting System of S7.4 and Bulb Replaceable Headlighting System of S7.5.

We are thinking of taking a new headlamp configuration into our design of headlamps which seems not to come under any of lighting systems abovementioned, as shown in the attached sheet-1.

It is a combination of the current systems, consisting of the integral beam headlighting and the bulb replaceable headlighting, and is a possible and reasonable construction for hybrid headlighting systems combining a new technology of HID headlighting a nd the conventional tungusten filament headlightings, we think. We would hereby ask for your kind advice as to whether the said combination of lighting systems could be accepted in use for the automobile headlamps under the current FMVSS No. 108.

Our intended configuration is just a conbination of lighting systems currently permitted in use, never raising argument on the safety and performance aspect, we believe.

If the configuration is not accepted just because it has not been provided in the wording of the lighting systems of FMVSS No. 108, we would like to petition an amendment of FMVSS No. 108 so that such a configuration as we intend might be accepted to use , by submitting the attached sheet-2 enclosed herewith.

Your kind and favourable attention to this matter would be greatly appreciated.

Attached Sheet 1

Combination of Headlighting Systems

4 Lamp System (Drawing omitted.)

Note:(1) Lower Beam Headlamp is designed to conform to the applicable requirement of S7.5. (2) Upper Beam Headlamp is designed to conform to the applicable requirements of S7.4. (3) Photometric design is in conformity with Fig. 15 of FMVSS No. 108.

2 Lamp System

(Drawing omitted.)

(1) Lower Beam Headlamp is designed to conform to the applicable requirement of S7.5. (2) Upper Beam Headlamp is designed to conform to the applicable requirement of S7.4. (3) Photometric design is in conformity with Fig. 17 of FMVSS No. 108.

Attached Sheet 2

Atten: Mr. Paul Jackson Rice Date: November 20, 1990

Petition for Amendment of FMVSS No. 108 (Lamp, reflective devices, and associated equipment) Combination of Integral Beam and Bulb Replaceable Headlighting System We would hereby petition to amend FMVSS No. 108, as belowmentioned, so that a combination of Integral Beam Headlamp and Bulb Replaceable Headlamp can be use for automobile headlamps;

S7 should be changed as follows;

S7. Each passenger car, multipurpose passenger vehicle, truck and bus shall be equipped with a headlighting system designed to conform to the requierments of S7.3, S7.4 or S7.5. Headlighting systems may be a combination of integral beam headlighting system and bulb replaceable headlighting system provided that each headlamp or part of headlamp meets the applicable requirements. In this case, photometric requirements of Fig. 15 or Fig. 17 shall be met according to the lamp system.