ID: aiam4997

"Dear Mr. Hecker: This responds to your letter of April 2, 199 concerning possible interpretations of section S5.1.4(c) of Federal Motor Vehicle Safety Standard No. 222, School bus passenger seating and crash protection, as it applies to the R-BARR Passenger Restraint System (R-BAR). (While your letter refers to section S5.1.2(c), you clarified in a telephone conversation with Mary Versailles of my staff that your concerns relate to section S5.1.4(c).) The R-BAR is a padded restraining device, and the ends of the device attach to the rear of a school bus seatback. The device folds down for the purpose of restraining the passengers seated in the next rearward seat. Your letter states that Micho Industries believes that: A. The standard is not applicable to the R-BAR passenger restraint. B. The R-BAR complies with the intent of Standard No. 222. To support these statements you offer the following reasons: 1. The R-BAR is not a fixed position device, nor is it a rigid component of the seat structure. 2. In the event of a rear impact, the R-BAR incorporates a design that allows it to move upward, and away, from the adjoining seat which would thus allow the minimum clearance as intended. 3. The standard in question (571.222, section S5.1.4(c)) was written without the authors having the benefit of knowledge of this type of device and thus allowances were not included for its possible use. The issue of whether Standard No. 222 is applicable to a device such as the R-BAR has been addressed previously by this agency. Enclosed are copies of four letters concerning similar devices (Mr. Joseph F. Mikoll, November 3, 1988, and March 10, 1989, The Honorable Robert J. Lagomarsino, January 8, 1990, and Mr. Scott K. Hiler, January 31, 1991). Those letters make it clear that if a device such as the R-BAR is installed in any new school bus, the school bus manufacturer must certify that the vehicle meets all applicable safety standards with the device installed. The letters also make it clear that such devices may not legally be installed in used school buses by commercial establishments such as repair businesses if the effect of such installation is to take the vehicle out of compliance with any safety standard. With respect to your assertion that the R-BAR complies with the intent of Standard No. 222, the National Traffic and Motor Vehicle Safety Act requires NHTSA to issue Federal motor vehicle safety standards that prescribe objective requirements. Under the Act, manufacturers must certify that their products comply with the requirements of all applicable standards and not merely with some alleged 'intent' of a standard. Further, manufacturers may not certify products based on speculation that the agency would have established different requirements had it known of a particular design. With regard to your specific concerns about S5.1.4(c), that section states that when a seat back is subjected to a specified force, '(t)he seat shall not deflect by an amount such that any part of the seat moves to within 4 inches of any part of another passenger seat in its originally installed position.' In the enclosed letter to Mr. Hiler, the agency stated that 'once the restraining bar is attached to the seatback, it is part of the seatback.' Therefore, the R-BAR would be considered a part of the seat subject to the requirements of S5.1.4.(c) Section S5.1.4(c)'s requirements are not limited to rigid components of a seat, and therefore the fact that the R-BAR is not a fixed position device is not relevant to the applicability of those requirements. With respect to your argument that the device will move upward and away in the event of a rear impact, Standard No. 222 sets forth a specific test procedure for the requirement specified in S5.1.4(c). Manufacturers are required to certify that a vehicle complies with the requirements of the standard when tested in accordance with that test procedure. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures";

ID: aiam5309

"Dear Mr. White: This responds to your letter of December 13, 1993 asking several questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413, November 2, 1992). Your questions and the response to each follows. 1. The effective date - is it the chassis manufacturer's date of completion, the final stage manufacturer's date of completion, or somewhere in between? The effective date for the November 2 final rule is May 2, 1994. Only vehicles manufactured on or after the effective date of an applicable requirement in a Federal motor vehicle safety standard must comply with that requirement. If a vehicle is manufactured in two or more stages, the final stage manufacturer is required to certify that the vehicle complies with 'the standards in effect on the date of manufacture of the incomplete vehicle, the date of final completion, or a date between those two dates.' (49 CFR Part 568.6). 2. Based on the formula for emergency exit space, is the area of the front service door to be included? Does this mean on a vehicle of 60 to 77 passengers, the only additional requirements beyond the front and rear doors is a left side exit door? The November 2 final rule requires additional emergency exit area (AEEA) for some buses. The amount, if any, of AEEA which must be provided is determined by subtracting the area of the front service door and either the area of the rear emergency door or the area of the side emergency door and the rear push- out window, depending on the configuration of the bus (S5.2.3.1). These are the minimum exits required on all buses. If AEEA is required, the first additional exit which must be installed is a left side emergency door (for a bus with a rear emergency door) or a right side emergency door (for a bus with a left side emergency door and a rear push-out window). The number of exits may vary for buses which carry the same number of passengers, because the amount of area credited for each exit is the area of daylight opening, and because different variations of types of exits are possible. However, in the regulatory evaluation for the final rule, the agency estimated that a bus would not be required to have a roof exit (the second type of additional exit required) unless the capacity was greater than 62 (for a bus with a rear emergency door) or 77 (for a bus with a left side emergency door and a rear push-out window). 3. The 'clear aisle space' required for exit to the proposed side emergency door, according to federal specifications, can be met with a flip-up type seat or a clear opening of 12', as measured from the back of the door forward. Are there any specifications, definitions, or descriptions provided as to what would be considered a 'flip seat'? The November 2 final rule allowed a flip-up seat to be adjacent to a side emergency exit door 'if the seat bottom pivots and automatically assumes and retains a vertical position when not in use, so that no portion of the seat bottom is within' the required 12 inch aisle to the exit (S5.4.2.1(a)(2)(ii)). The agency did not otherwise define a flip-up seat, nor did it include any performance requirements for these seats. 4. Also, there is concern regarding school buses that are equipped with the 'flip seat' by the emergency door opening and the possibility of school children, either intentionally or accidently, unlatching the door latch mechanism. Are the door latch mechanisms to be equipped to help prevent this from occurring? Standard No. 217 includes requirements for the type of motion and force required to release an emergency exit (S5.3.3). One of these requirements is that the motion to release a door must be upward from inside the bus (upward or pull-type for school buses with a gross vehicle weight rating of 4,536 kilograms or less). This is intended to lessen the chance of a door accidently being opened, without unnecessarily making the exit more complicated to open in an emergency. In addition, warning alarms are required for door and window exits to notify the driver that the exit has been opened. I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: 06-007782jeg

ID: nht88-1.98

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Wayne Apple

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/19/89 letter from Stephen P. Wood to Rod Willaredt (A33; Std. 108); 5/17/89 letter from Rod Willaredt to Taylor Vinson; 2/19/88 letter from Erika Z. Jones to Charles Wilson; 7/11/88 letter from Erika Z. Jones to Willaim J. Stephenson

TEXT:

Mr. Wayne Apple 14738 Bronson Avenue San Jose, CA 95124

Dear Mr. Apple:

This is in reply to your letter of December 29. 1987, in which you asked whether a U-Turn Indicator "is reasonable, within federal regulations or specifications, and if the Department of Transportation has interest in the concept and/or product."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment contains specifications for original and replacement lighting equipment. None of these specifications is for a U-Turn indicator. However, a U-Turn indicator is acceptable as original vehicle equipment provided it does not impair the effectiveness of the lighting equipment that the standard requires, such as turn signal lamps, headlamps, taillamps, and stop lamps. Your proposed specifications recognize the i mportance of differentiation between the left turn signal and the U-Turn indicator, and we encourage you to minimize the possibility of impairment.

Standard No. 108 does not cover a U-Turn indicator as an aftermarket device, but it is subject to the general restriction that its installation must not render inoperative, in whole or part, any lamp reflective device, or associated equipment that was in stalled pursuant to Standard No. 108. (15 U.S.C. 1397 (a)(2)(A)) The legibility of use of an aftermarket device of this nature would be determinable under the laws of the State in which a vehicle equipped with it is registered or operated. The American A ssociation of Motor Vehicle Administrators, 1201 Connecticut Ave. N.W., Washington, D.C. 20036 may be able to advise you further on State laws.

Accident data available to the agency does not permit us to identify specific crashes in which a vehicle is making a U-Turn. However, an analysis of data from one of our files that contains information on almost 3 million crashes indicates that the gener al type of crash for which U-Turn crashes are a subset (left-turning crashes) constitutes less than 6% of the total crash experience. Thus, we believe that the number of U-Turn crashes is substantially less than 6% represented by the broader category of crashes involving left-turning vehicles.

We do not know the basis for your statement that your U-turn indicator "will probably reduce accidents involving U-turns by over thirty percent". However, the agency is interested in exploring concepts that could enhance vehicle safety. I am providing ou r Office of Research and Development with a copy of your letter for such further comment as may be warranted.

We appreciate your interest in safety.

Sincerely,

Erika Z. Jones Chief Counsel

CC: Michael Finkelstein

December 29, 1987

Erika Jones, Chief Counsel Legal Office, Room 5219 D.O.T. Headquarters 400 7th Street Southwest Washington D.C. 20590

Dear Erika,

I have been instructed by the Office of Vehicle Compliance to write you concerning a new Safety feature I have designed. I am interested in receiving feedback as to whether my idea is reasonable, within federal regulations or specifications, and if the D epartment of Transportation has interest in the concept and/or product.

The reason I have designed this Safety feature, which is called an Automobile U-turn Directional Indicator was to reduce the number of automobile accidents in which U turns are involved. My sister and several acquaintances, have suffered serious injuries , primarily due to the lack of communication between drivers, simply because they do not have a tool by which to communicate.

The solution is simple and at a very low cost, yet it could save the lives of many.

Please review the attached documentation, and feel free to write or call me if you have any questions or require additional information. Thank you for your time and effort.

Sincerely,

Wayne Apple 14738 Bronson Ave. San Jose, CA 95124 (408) 377-0174 Home (408) 986-2526 Work

AUTOMOBILE U-TURN DIRECTIONAL INDICATOR SAFETY FIRST

Far too many accidents involve U-turns, and most likely they are of a serious nature. The ability to make a U-turn is much too convenient to try to strip away from the American public. A better and simple means of communicating the intention of making a U-turn is in order; and I have the solution. Implementing this simple tool will probably reduce accidents involving U-turns by over thirty percent.

STATEMENT OF PROBLEM

Situation A: You are in you automobile waiting in the left turn lane with or without a signal light. There is an automobile in front of you, and one behind you, waiting as well. When it is time to turn, the car ahead of you starts accelerating through th e turn. You accelerate as well, and so does the car behind you. Suddenly, midway through the turn, the car in front of you whips into a sharp U-turn, without any means of warning. If you are not quick to react, you clip the rear end of the car as it make s it U-turn, sending it into a spin, hopefully avoiding any serious injuries. If you were quick to react, you end up slamming on your brakes and either slide into the car making the U-turn, or have the car behind you crash into your rear end, slamming yo u into the car making the U-turn. Hopefully, no serious injuries result. Had you known the driver was going to make a U-turn all along you would have been prepared for it from the start of the turn. No accident would have resulted.

Situation B: You are driving your automobile down the street and approach an intersection. There is a car with sitting in the oncoming traffic left hand turn lane. They have activated their left hand turn indicator. There are several cars following behin d your car. The oncoming car in the left hand turn lane believing there is enough time to make the turn, and there probably is. You slow down, so do the cars behind you, to allow for the turning car to pass through the intersection. Suddenly the car whip s into a U-turn. There is not enough time to react. Your car crashes into the U-turn car. One or two of the cars behind you crash into your car's rear end. Hopefully no serious injuries result, but they usually do in such circumstances. Had you known the car was planning to make a U-turn initially, you would have applied the brakes harder when the driver first began the turn, and hopefully avoided any accident at all situation C: You are waiting at a four way intersection in your automobile to make a ri ght hand turn. There is a car waiting in the cross traffic left hand turn lane, ahead and to your right, with the left turn indicator blinking brightly. Right hand turns are legal in your state on red lights. There is a break in traffic. You begin to tur n to the right and into the lane. The car in the left hand turn lane begins to turn down the road you had just traveled on. Suddenly, the driver of the car turning left, who was paying more attention to the oncoming traffic, whips the steering wheel hard to make a sharp U-turn, which is legal at this intersection. The two cars collide, crushing the front ends of both automobiles. You would not have made the turn to the right had you suspected the driver of the other car would be making a U-turn.

PRODUCT SOLUTION

The need stated in the problem situations above is a means to notify other drivers when you are planning to make a U-turn, and be able to discern it from a left hand turn signal; thus, I have designed a product with the means to satisfy this need.

The product is an Automobile U-turn Directional Indicator (U-turn Blinker), which is to be mounted on the front and rear driver's side of the car next to the left hand turn indicator. They are to be activated by a four position turn indicator switch, tha t utilizes the fourth down position to activate the U-turn signal. It is recommended that there be additional resistance in moving from the third position (left turn) to the fourth position (U-turn) to alleviate mistakes, as well as a U-turn dash light.

PRODUCT SPECIFICATIONS

* Four position indicator switch. Fourth position down is U-turn. Resistance between third and fourth position.

* The rear U-turn directional indicator light assembly is mounted near the rear left hand turn indicator. The arrow should start at the lower right portion of the light housing, head straight to the top, curve to the left, then point straight downward, a s if the driver trailing the car were looking at a posted U-turn sign.

* The front U-turn directional indicator light assembly is mounted near the front left hand turn indicator. The arrow should start at the upper left hand portion of the light housing, head straight down, bend to the right then head straight up.

PRODUCT SPECIFICATIONS Cont...

* The black area contained within the U-turn light housing assembly which blacks out the portion of the light assembly to outline the arrow, should be painted on, or preferably, be made of black rubber and glued onto the reflector plastic.

* The reflector portion of the U-turn light housing assembly should be a different color than the left hand turn indicator, to better differentiate the two. A cross between yellow and lime green would be noticeable.

* The size and shape of the U-turn directional housing is up to the discretion of the manufacturer, with a minimum of three square inches.

* The intensity of the U-turn indicator light should be equal to, or brighter than, the left hand turn indicator. The color and arrow shape will assist in the differentiation.

* Matching reflector plates can be used on the right side of the car for cosmetics and balance.

* A U-turn dash light indicator should be located near the dash turn indicator light, preferably the same color as the reflector plate.

SUMMARY

Communications between automobile drivers needs to improve. Clearly notifying other driver's your intentions can reduce the number of accidents by over fifty percent. Having the tools to better communicate to other drivers is a necessity. The U-turn dire ctional indicator is one of those tools to making America's roads a safer place.

ID: 22705.drn

Mr. Bob Douglas
American Transportation Corporation
751 S. Harkrider
Conway, AR 72032





Dear Mr. Douglas:

This responds to your request that we write a letter to the Government of Israel's Minister of Transportation. You wrote that you needed this letter because you are:

working to secure a bid for commercial buses to be built here in Conway Arkansas and to be exported to Israel. They have requested that we provide them a letter that states that FMVSS 220 is an official regulation and that the regulation only pertains to school buses. They require that this letter come from NHTSA.

The following provides the information you request.

The National Traffic and Motor Vehicle Safety Act was enacted on September 9, 1966,

(P.L. 85-563), in order to reduce traffic accidents, deaths and injuries resulting from traffic accidents. This law, now codified as chapter 301 of title 49, United States Code, directs the U.S. Secretary of Transportation to establish Federal motor vehicle safety standards (FMVSSs), to which motor vehicles and motor vehicle equipment must conform and to which the manufacturers of such vehicles or equipment must certify compliance. The responsibility to establish FMVSSs has been delegated (by regulation) to the National Highway Traffic Safety Administration (NHTSA).

It is my understanding that the Israeli Government wishes to procure buses that are not school buses. There are no Federal motor vehicle safety standards on rollover protection that apply to non-school buses. NHTSA has issued FMVSS 220 (49 CFR Section 571.220), School bus rollover protection to establish performance requirements for school bus rollover protection, but does not apply this standard to non-school buses.

If you wish further information, please write to me at this address or contact Dorothy Nakama of my staff at: (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel
ref:220
d.3/6/01

ID: 1985-01.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/27/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. H. Horiyoshi Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Horiyoshi Executive Vice President and General Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, MI 48018

Dear Mr. Horiyoshi:

This is in reply to your letter of November 21, 1984, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it would apply to a contemplated parking lamp system.

Usually passenger cars are designed with two parking lamps, one on each side of the vehicle front. Mazda would have two such lamps on each vehicle side, each of the two lamps flanking the headlamp. You have asked whether, in determining the H-V axis, one takes the axis as the center of each lamp, or should one consider the pair a single device and place the H-V axis at the midpoint between them.

Standard No. 108 requires passenger cars to be equipped with a minimum of two parking lamps, located "as far apart as practicable." Therefore, the outermost parking lamp, (the one located between the turn signal lamp and the headlamp) is the lamp that must meet the parking lamp requirements of Standard No. 108, and the H-V axis for purposes of compliance would be determined at the center of the lens of that lamp. Supplementary lighting equipment is permissible under Standard No. 108 and does not have to meet the standard's requirements, but it must not impair the effectiveness of the lighting equipment required by the standard (paragraph S4.1.3). Because of the difference in candela between parking lamps and headlamps, information available to us does not indicate that your supplementary parking lamp would have this effect, and consequently, the design would be permitted.

I hope that this answers your questions.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

ID: 1985-03.1

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. H. Moriyoshi

TITLE: FMVSS INTERPRETATION

TEXT:

June 28, 1985 Mr. H. Moriyoshi Executive Vice President and General Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, Michigan 48018 Dear Mr. Moriyoshi: This is in reply to your letter of June 3, 1985, asking for an interpretation of Motor Vehicle Safety Standard No. 108 regarding requirements for the center high-mounted stop lamp/ You reference an agency letter of July 30, 1980, to Volkswagen of America in which the Chief Counsel concluded that placement of the stop lamps and taillamps on the deck lid could be viewed as a defect in performance requiring notification and remedy. You have asked, in essence, how this related to Standard No. 108's present allowance of a center high-mounted stop lamp mounted on a vehicle's decklid, hatch, or tailgate. The assumption underlying the agency's 1980 letter was that a defect could exist if all a vehicle's stop lamps and taillamps were mounted on the decklid, where their signals could be unobserved or obscured if the lid were in any position other than closed. The center high-mount stop lamp, on the other hand, while an item of required equipment, is nevertheless a supplementary stop lamp. Even if the deck, hatch, or tailgate upon which it is mounted should be open, following drivers may still observe the signals of the primary stop lamps remaining on the body. You have asked that we also discuss the implications of a stop lamp and taillamp constructed so that a portion is fixed to the body of the vehicle adjacent to the decklid opening and the remaining portion is mounted on the outboard area of the decklid. Compliance of a vehicle is determined with respect to its normal driving position, that is to say, with the tailgate, hatch, or decklid closed. However, in order to obviate any possibility of the existence of a safety-related defect, we recommend that the portion of the lamp that is mounted on the body itself comply with the minimum requirements of Standard No. 108 for a single compartment stop lamp or taillamp. I hope that this answers your questions. Sincerely, Original Signed by Jeffrey R. Miller Chief Counsel

ID: 15215.wkm

Mr. Carlos Fracaroli
Pirelli
Av. Alexandre de Gusmâo
487-09110-900
Santo André, SP Brasil

Dear Mr. Fracaroli:

Please pardon the delay in responding to your letter in which you inquired about tolerances in the ambient temperature requirements of Federal motor vehicle safety standard (FMVSS) No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR 571.119), and 49 CFR 575.104, Uniform Tire Quality Grading Standards. You stated that you found no such tolerances in the standards and asked how you should calibrate your laboratory if none exist, since ambient temperatures can oscillate 5 degrees Fahrenheit (F).

You are correct that the above standards do not provide for tolerances with respect to the testing temperatures of tires. All of our FMVSSs specify minimum performance requirements. Thus, manufacturers must design and build the products to meet or exceed the specified performance. Since increased temperature is generally detrimental to tire performance, manufacturers must ensure that each tire meets the required performance at the temperature specified in the standard, in this case, 95 degrees F. Given the variability in laboratory equipment as you correctly noted, however, the agency allows an ambient temperature tolerance in our compliance testing of +0F-10F. The +0F ensures that the actual temperature will never oscillate above 95F. That upper limit ensures that we do not exceed the requirements of the standard, which would invalidate the test. For your information, please find enclosed extracts from this agency's Laboratory Procedures for Tire Testing and Data Reporting, DOT publication No. TP-119-04, May, 1988, applicable to FMVSS No. 119, and Laboratory Procedures for Tire Temperature Resistance Testing, DOT publication No. TP-UTQG-H-01, May 25, 1979, applicable to the UTQGS. Both publications are available from this agency, ATTN: NAD-40.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact this office at this address or by Fax at 011-202- 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosures
ref:119#575
d.10/8/97

ID: 15302.ztv

Mr. Dennis G. Moore
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

This is in reply to your letter of May 28, 1997, to Samuel J. Dubbin, the former Chief Counsel of this agency. You ask for a "reconsideration" of his interpretation letter to you of July 29, 1996.

That letter informed you that we saw no conflict between California Vehicle Code Sec. 25100(e) requiring clearance lamps to be visible from all distances between 500 feet and 50 feet to the front and rear of the vehicle, and paragraph S5.3.1.1.1 of Federal Motor Vehicle Safety Standard No. 108 providing that clearance lamps located other than on the front and rear need not be visible at 45 degrees inboard. In our opinion, S5.3.1.1.1 did not relieve clearance lamps of the requirement that they be visible and meet minimum photometric requirements "directly to the rear" and at 45 degrees outboard.

You disagree with this interpretation, commenting that "perhaps one could see at least one of the so-called Clearance lights 'to the rear' if one were in the left or right lane directly adjacent to the lane" in which the vehicle carrying the clearance lamps were traveling. We do not think that our interpretation was mistaken. It remains our belief that a clearance lamp located other than on the rear of a vehicle, such as on a fender, but which is visible directly to the rear, will be visible without reference to an adjacent lane, and will be visible from 50 to 500 feet directly to the rear of the vehicle as specified by CVC Sec. 25100(e). The issue of whether a particular manufacturer may have violated the standard by recessing its clearance lamps on the side of a vehicle so that they are not visible and do not meet applicable photometric requirements from the rear is a different issue, and does not call into question our prior interpretations.

We appreciate your bringing this matter to our attention.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:7/17/97

ID: 19623.ztv

Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

Dear Mr. Suzuki:

This is in reply to your letter concerning the testing of reflectors of replaceable lens headlamps for chemical and corrosion resistance. I apologize for the delay in our response.

Under the test procedure established by S8.10.1(c), after test fluids are applied to headlamp reflectors, the reflectors "shall be wiped clean with a soft cotton cloth . . . ." You remark that the force applied to the reflector during cleaning is not specified, noting that if Stanley wipes the reflector "so gently that the surface would not be damaged, the headlamp will meet the requirements prescribed in S7.4(h)(2)," but, "on the other hand, if we wipe the reflector without any carefulness, the surface might be damaged." In your opinion, this means that "some kind of attention is needed to meet the requirement of S7.4(h)(2)." You ask "if such kind of attention is permitted under S8.10.1(c)."

S5.8.11 of Standard No. 108 requires that a replacement lens for a replaceable lens headlamp must be provided with a replacement seal in a package "that includes instructions for the removal and replacement of the lens, the cleaning of the reflector, and the sealing of the replacement lens to the reflector assembly." Although you reference only the chemical resistance test of S8.10.1(c), we note that the corrosion test contains a specific requirement that "the reflector shall be cleaned according to the instructions supplied with the headlamp manufacturer's replacement lens" (S8.10.2(b)). The instructions for the cleaning of the reflector may specify the force recommended to be applied for this operation.

If the instructions do not specify the force needed to wipe the reflector clean, we would interpret the test procedure as encompassing the range of force levels that technicians would reasonably employ to perform the required task. Thus, in a compliance test where instructions are silent as to the force to be used, no special care would be taken to use the minimum possible force, nor would the technician deliberately use excessive force.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/29/99