ID: nht90-3.56

TYPE: Interpretation-NHTSA

DATE: August 14, 1990

FROM: Paul G. Scully -- Vice President, Peterson Manufacturing Company

TO: Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12-27-90 to Paul G. Scully from Paul Jackson Rice (A37; Std. 108)

TEXT:

A few days ago, one of our fleet customers telephoned our Sales Department and advised that they were notified that the Peterson reflex reflectors used on their vehicles were not legal because they did not have the SAE-A marking one them. Sergeant Harti gan of the Traffic Enforcement Division was under the impression that SAE markings were required because they are still shown as a requirement in the regulations of the Office of Motor Carrier Safety. As you know, Federal Safety Standard 108 requirement s do not mandate the use of SAE markings on any regulated products. I believe this is the third instance in the past two years (the other two occurring in Texas) where police officials have mistakenly advised our customers that our products were illegal and should be removed. The reflex reflector products in questions do have the DOT markings on them and we certify that these products are in full compliance with Federal Safety Standards for reflex reflectors. These thin, flexible reflectors are diecu t which explains why it would be somewhat difficult and costly to put the SAE impressions on this thin film; therefore, we elected not to do it even though the SAE code markings are, in fact, used on all of our other products. It is somewhat ironic that Peterson Manufacturing Company led the industry effort to require SAE markings as part of the MVSS 108 requirements. Our company initiated the petition to require code markings, but after about one year of study, we were advised that this petition had been denied, even though the majority of the departments in both the NHTSA and the Office of Motor Carrier Safety agreed with our petition. I am sure that Messrs. Felrice and Helmuth remember our many discussions concerning these markings.

These reflex reflectors are sold in large volumes both to original equipment manufacturers and as replacement products throughout the nation and, I emphasize again that they fully comply with all requirements. It is quite unfortunate that another agency of the Department of Transportation, the OMCS, still retains these marking requirements in their publication. Again, we would be pleased to have all regulated items marked as per our petition because it would avoid situations like these, as well as impe de the importation of many illegal products from the Orient which are never identified as to the source.

We would like to request that you promptly notify the Tucson Police Department that these products are not required to have SAE markings in order to be perfectly legal reflectors. I would also like to once again appeal for a uniform set of regulations b etween the two government agencies involved. We can probably expect similar misunderstandings to occur by other municipal authorities unless some action is taken.

ID: nht90-3.57

TYPE: INTERPRETATION-NHTSA

DATE: 08/15/90

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: NORMAN B. SCOTT, JR., SNUG SEAT, INC.

TITLE: NONE

ATTACHMT: Letter dated 6-15-90 to E. T. Jones from N. B. Scott, Jr.; (OCC 4904); also attached to copy of photograph

TEXT:

This responds to your letter seeking this agency's opinion on the procedures to be followed in testing a new car bed designed to transport "Low Birth Weight" (LBW) infants in a supine or prone position. Your letter and enclosed photograph indicate that you have tested the car bed with the six-month-old dummy specified in 49 CFR S572.25. While the dummy's torso fits in the car bed, the legs did not. You state that "(a) dynamic crash test showed the dummy staying in the shell and the shell maintaining it's integrity." You asked whether this testing would be "adequate relative to the present standard."

By way of introduction, the National Traffic and Motor Vehicle Safety Act (Safety Act) does not require a manufacturer to test its products only in the manner specified in the relevant safety standard, or even to test its products at all. A manufacturer may choose any means of evaluating its products to determine whether the vehicle or item of equipment complies with the requirements of the safety standards, provided, however that the manufacturer assures that the vehicle or equipment will comply with the safety standards when tested by the agency according to the procedures specified in the standard.

If agency testing shows an apparent noncompliance exists with a vehicle or item of equipment, the manufacturer is asked to show the basis for its certification that the vehicle or equipment complies with the relevant safety standard or standards. If in fact there is a noncompliance, the manufacturer is subject to civil penalties under the Safety Act unless it can establish that it exercised "due care" in the design and manufacture of the product and in the checks (through actual testing, computer simul ation, engineering analysis, or other means) to ensure compliance.

This agency has long said that it is unable to judge what efforts would constitute "due care" in advance of the actual circumstances in which a noncompliance occurs. What constitutes "due care" in a particular case depends on all relevant facts, includi ng such things as the limitations of current technology, the availability of test equipment, the size of the manufacturer, and, above all, the diligence exercised by the manufacturer.

However, the agency can say that your company's decision to use the smallest test dummy included in Part 572 (the six month old test dummy) to conduct certification testing and to conduct the testing in accordance with the procedures specified in Standar d No. 213, Child Restraint Systems, appears reasonable. If that test dummy cannot be positioned entirely within the car bed, it also appears reasonable to position the

test dummy's head and torso completely within the car bed and allow the test dummy's feet and part of the legs to fall outside of the car bed. This is because S5.1.3.3 of Standard No. 213 requires all portions of the test dummy's head and torso to be ret ained within the confines of the car bed, so the head and torso must obviously begin within the car bed.

You should also note that, while the exercise of "due care, may relieve a manufacturer of liability for civil penalties in connection with the manufacture and sale of noncomplying vehicles or equipment, it does not relieve a manufacturer of the responsib ility to notify purchasers of the noncompliance and remedy the noncompliance without charge to the purchasers, if either the manufacturer or this agency determines that vehicles or items of equipment do not comply with all applicable safety standards.

I hope this explanation is helpful. If you have some further questions or need further information on this subject, please contact Mary Versailles of my staff at our address, or telephone (202) 366-2992.

ID: nht90-3.58

TYPE: INTERPRETATION-NHTSA

DATE: 08/15/90

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: VAUGHN CRAWLEY -- VICE PRESIDENT, MONITOR MANUFACTURING CO.

TITLE: NONE

ATTACHMT: LETTER DATED 11-14-89 TO S. WOOD FROM V. CRAWLEY; (OCC 4160)

TEXT:

This responds to your letter seeking an explanation of a manufacturer's responsibilities under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., "the Safety Act"). I apologize for the delay in this response. You were particular ly concerned with van converters' certifications of compliance with standards No. 207, Seating Systems, and No. 210, Seat Belt Assembly Anchorages. You stated that, in a van conversion, the pedestal, the seat, and the safety belts may all be supplied by different manufacturers. You also stated that each of these components might be accompanied by test reports and engineering analyses showing that the component will, if properly installed, comply with the requirements of the safety standards. You aske d whether the test reports and engineering analyses of each of the individual components could be combined to form the basis for certifying compliance with Standards No. 207 and 210, or whether the assembled seating system, as installed in the vehicle wo uld have to be tested. I am pleased to have this opportunity to explain our laws and regulations for you.

Each of this agency's safety standards specifies the test conditions and procedures that this agency will use to evaluate the performance of the vehicle or equipment being tested for compliance with the particular safety standard. NHTSA precisely follow s each of the specified test procedures and conditions when conducting its compliance testing. However, the Safety Act does not require a manufacturer to test its products only in the manner specified in the relevant safety standard, or even to test the products at all. A manufacturer may choose any means of evaluating its products to determine whether the vehicle or item of equipment complies with the requirements of the safety standards, provided, however, that the manufacturer assures that the vehic le or equipment will comply with the safety standards when tested by the agency according to the procedures specified in the standard.

If the agency testing shows an apparent noncompliance exists with a vehicle or item of equipment, the manufacturer is asked to show the basis for its certification that the vehicle or equipment complies with the relevant safety standard or standards. If in fact there is a noncompliance, the manufacturer is subject to civil penalties under the Safety Act unless it can establish that it exercised "due care" in the design and manufacture of the product and in the checks (through actual testing, computer s imulation, engineering analyses, or other means) to ensure compliance, but nevertheless did not have reason to know that the vehicle or item of equipment did not in fact comply with the safety standards.

With respect to your question about whether additional testing needs to be done by your company for the vans you manufacture or if you can simply

rely on the tests done by the component manufacturers, this agency has long said that it is unable to judge what efforts would constitute "due care" in advance of the actual circumstances in which a noncompliance occurs. What constitutes "due care" in a particular case depends on all relevant facts, including such things as the limitations of current technology, the availability of test equipment, the size of the manufacturer, and, above all, the diligence exercised by the manufacturer. NHTSA would loo k to such things as the test results for the individual components mentioned in your letter, the installation of those components by your company, the quality control procedures used by your company, and any other relevant factors to determine whether yo ur company had exercised due care to ensure that your vans complied with all relevant safety standards.

However, it is not clear that a manufacturer could show that it exercised "due care" based solely on the test results for the individual components mentioned in your letter. As explained above, a van converter is required to assure that its vans will co mply with the safety standards when tested by the agency in accordance with the procedures specified in the standards. It would be difficult to establish that a manufacturer had exercised "due care" to satisfy its responsibilities under Standards No. 207 and 210, unless the manufacturer had some evaluation of the performance of the assembled seating systems and safety belts installed in the vehicles in question. Test results for the individual components of the seating systems may not give a van conver ter enough information about the seating system as a whole to make such an evaluation.

You should also note that, while the exercise of "due care" may relieve a manufacturer of liability for civil penalties in connection with the manufacture and sale of noncomplying vehicles or equipment, it does not relieve a manufacturer of the responsib ility to notify purchasers of the noncompliance and remedy the noncompliance without charge to the purchasers, if either the manufacturer or this agency determines that vehicles or items of equipment do not comply with all applicable safety standards.

I hope this explanation is helpful. Please contact Mr. Kenneth Weinstein, our Assistant chief Counsel for Litigation, at (202) 366-5263 if you have any further questions or would like some additional information on this subject.

ID: nht90-3.59

TYPE: Interpretation-NHTSA

DATE: August 16, 1990

FROM: Edward R. Heussner -- Consultant, Comp U Tence

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Interpretation of Requirements for FMVSS 219 - Windshield Intrusion Zone

ATTACHMT: Attached to letter dated 1-4-91 to Edward R. Heussner from Paul Jackson Rice (A37; Std. 219; VSA 108(b)(2)

TEXT:

I am working on the compliance documentation for an automobile manufacturer.

In the process of studying the data, charts and films of the impact tests I noted the windshield wiper would pass thru the "protected zone" on some tests. I called your office on Friday August 10 and talked with Dorthy Nakama. My initial question of he r was is the windshield wiper considered to be a component . . . "normally in contact with the windshield" . . . as per the standard. She assured me that the wiper fits that definition and thus is not a problem.

We then discussed the next phrase regarding "penetration." The standard states that in the area immediately below the protected zone ... no such part of the vehicle shall penetrate the inner surface of that portion of the windshield, within the DLO, bel ow the protected zone.

My question revolves around what constitutes penetration? Specifically does penetration occur when the windshield is deformed in the region . . . or does some vehicle component have to actually protrude thru and puncture the "glass-plastic" in the area in question? I used the analogy of a bowling ball being dropped on a windshield. The dimple so created would certainly protrude inward yet I would not have considered it to have penetrated. Thus, in order for penetration to have occurred does some veh icle component have to go thru the windshield or is "obscuring" of the glass sufficient to demonstrate failure in this instance?

I have one other question regarding the test procedure for FMVSS 219. The standard defines a protected zone, degree of penetration and method of measurement. It is my understanding that many organizations test vehicles for several standards simultaneou sly (i.e. 208, 212, 219 & 301) and consequently considerable data is lost when the protected zone styrofoam template is glued to the windshield. Thus it is quite common to use the results of this multi-standard test to prove compliance to 219 under a NH TSA approved deviation to the stated approach.

Is engineering judgement acceptable to the agency in this instance. That is to say that analysis of the films could easily show nothing came near the protected zone. However, if some vehicle component did in fact "approach" the zone would another test, just for 219, be required.

Film analysis is quite advanced today, but tracing the path of an object to within 1/4" of an "imaginary surface" is probably expecting too much. Your comments on this issue would be welcome. If in fact the practice is to not

use the styrofoam template, perhaps the standard should be revised to reflect this. The alternative is very costly. Full vehicle barrier tests cost in excess of $100,000. At a nominal $1000 profit per sale, this translates into 100 sales just for that test. I would suspect that $100,000 plus dollars could be better spent towards a safer vehicle.

Thank you for your consideration of these questions, your prompt reply would be greatly appreciated. Keep smiling and have a super day.

ID: nht90-3.6

TYPE: Interpretation-NHTSA

DATE: July 3, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Charles T. Thomas -- Prestige Travel

TITLE: None

ATTACHMT: Undated letter to NHTSA Chief Counsel from Charles T. Thomas (OCC-4685)

TEXT:

This is in reply to your recent undated letter asking for a waiver of one of the requirements of 49 CFR 591.5(g) for persons working outside the United States and seeking to import a nonconforming vehicle, i.e., the requirement that "the importer's assigned place of employment has been outside the United States at all times between October 31, 1988, and the date the vehicle is entered into the United States." You are able to meet the other requirements of paragraph (g), but you returned to the United States in September 1988 after a 12-year employment abroad, and your 1985 Jaguar remains in Germany.

We are sorry that we are unable to provide the waiver you seek. This specific requirement was established by Congress as part of an exception to more rigorous requirements that became effective on, and applicable to, vehicles imported on and after January 31, 1990, of this year. Further, Congress did not provide us with any authority to waive this requirement. These provisions were added to the National Traffic and Motor Vehicle Safety Act by the Imported Vehicle Safety Compliance Act of 1988, Public Law 100-562.

However, our inability to waive this requirement does not mean that you will be unable to import your car. Under its new authority, the agency has tentatively determined that 1985 Jaguar automobiles are eligible for importation (as well as a number of other cars). Public comments on the tentative determinations were due in mid-May. After a final determination is made, and assuming that it is favorable, you may then import your Jaguar pursuant to the requirements of 49 CFR 591.5(f). In other words, you may import the vehicle either through an importer registered with this agency as one who will certify compliance of the Jaguar with Federal safety standards, or by yourself upon demonstration that you have a contract with a registered importer.

I enclose a copy of Part 591 for your information, as well as a list of registered importers approved as of April 13. We anticipate a final determination on vehicle eligibility this summer. If you wish to inquire as to the status of the determination, or to obtain an updated list of registered importers, please address your further correspondence to Director, Office of Vehicle Safety Compliance, National Highway Traffic Safety Administration, Washington, D.C. 20590.

(List of registered importers is omitted.)

ID: nht90-3.60

TYPE: Interpretation-NHTSA

DATE: August 16, 1990

FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Reference: 49 CFR, Part 571.221 School Bus Body Joint Strength

ATTACHMT: Attached to letter dated 1-14-91 from Paul J. Rice to Thomas D. Turner (A37; Std. 221); Also attached to undated letter from Frank Berndt to W.G. Milby; Also attached to letter dated 3-18-77 from Frank Berndt to W.G. Milby

TEXT:

Section S4 of the referenced standard provides the following definition:

"Body panel joint" means the area of contact or close proximity between the edges of a body panel and another body component, excluding spaces designed for ventilation or another functional purpose, and excluding doors, windows, and maintenance access pa nels.

In an April 26, 1976 letter to Blue Bird (reference N40-30) NHTSA stated: "Your assumption that components located entirely below the level of the floor line are not subject to the standard is correct."

The enclosed drawing 1519834 illustrates the joints of a Blue Bird stepwell to the Number 1 and 2 floor sections. Since the stepwell is a space designed for a functional purpose, it is our understanding that it is excluded from the requirements of the s tandard. The fact that the actual joint and all components of the stepwell are located entirely below the level of the floor line also constitutes the basis for exemption from the standard.

Based on these facts, it is Blue Bird's interpretation that the joints of the stepwell to the floor sections, as shown in drawing 1519834 are not subject to the joint strength requirements of FMVSS 221. We request your early consideration of this matter and confirmation that our interpretation is correct.

Attachment

Correspondence Log Wednesday 09/19/90 11:41 am For: BURRILL, Peggy Entry Number: 5110 Date Received: 08/21/90

Correspondence Date: 08/16/90 Entry Type: LTR Received from Company: Blue Bird Person: Thomas D. TurnerRE: Req. interpretation of FMVSS 221 as it pertains to the stepwell. See attached drawing 1519834 Routed to: NCC-20 *** 8/21/90 Follow up date: 10/09/90 Response date: / / Referred to: DG Filed:

ID: nht90-3.61

TYPE: Interpretation-NHTSA

DATE: August 20, 1990

FROM: Harry B. Skinner -- Chief, Traffic Engineering Division, Office of Traffic Operations, NHTSA

TO: Oliver M. Sprangers -- A. T. Kearney, Inc.

TITLE: Re HTO-21

ATTACHMT: Attached to letter dated 6-27-90 from Olivier M. Sprangers to James T. Brooks; Also attached to letter dated 1-8-91 from Paul J. Rice to Olivier M. Sprangers (A37; Std. 125)

TEXT:

We have received your letter of June 27 and forwarded your request to the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA) for response.

Personnel from the NHTSA will be able to better evaluate your safety device than our staff member, Mr. James T. Brooks.

Your interest in promoting highway safety is greatly appreciated. If we can be of further assistance, please let us know.

ID: nht90-3.62

TYPE: INTERPRETATION-NHTSA

DATE: 08/22/90

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: HANNO WESTERMANN--HELLA KG HUECK & CO.

TITLE: NONE

ATTACHMT: LETTER DATED 2-6-87 TO DR. BURGETT FROM HANNS-OUTFRIED WETERMANN; ALSO ATTACHED TO GRAPHS (INFORMATION OMITTED)

TEXT:

This is in reply to your letter to Dr. Burgett of this agency with respect to "multi bulb devices", specifically "how the requirements for one-, two-, or three compartment lamps (lighted sections) as it is documented in FMVSS No. 108, Figure 1b have to b e interpreted. . . ." You have asked this question because "Hella would like to equip motor vehicles with signalling devices which have--opposite to conventional lamps--a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb." Your question assumes that Standard No. 108 is to be interpreted in a manner that equates the number of lighted sections with the number of bulbs providing the light. Finally, you have stated that the total area of the lamp is not larger than current one-co mpartment lamps.

We regret the delay in responding to your letter, but we have recently completed rulemaking, begun in September 1988, which is relevant to your question. On May 15, 1990, an amendment to Standard No. 108 was published, effective December 1, 1990, the ef fect of which is to restrict Figure lb to replacement equipment. I enclose a copy of the amendment for your information.

Your question relates to "signalling devices" for new motor vehicles, and Figure lb shows that, specifically, you refer to turn signal lamps. Beginning December 1, 1990, Standard No. 108 will specify two different standards for turn signal lamps. If the lamp is intended for use on multipurpose passenger vehicles, trucks, buses, and trailers whose overall width is 80 inches or more, it must be designed to conform to SAE Standard J1395 APR85 "Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width." SAE J1395 also provides that these lamps may be used on vehicles less than this width, except for passenger cars. If a motor vehicle is not equipped with a turn signal lamp designed to conform to SAE J1395, it must be equipped with a t urn signal lamp designed to conform to SAE Standard J588 NOV84 "Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width."

In the May 1990 amendments, section S3 of Standard No. 108 was amended to add a definition for "Multiple Compartment Lamp". such a lamp is "a device which gives its indication by two or more separately lighted areas which are joined by one or more common parts, such as a housing or lens." The multiple bulb device that you described appears to meet this definition.

SAE J1395 establishes luminous intensity minima and maxima photometric requirements without reference to either compartments or lighted sections, and all that is required is for the lamp to comply at the individual test points specified. New section S5. 1.1.31 clarifies that measurements of a multiple compartment turn signal lamp on vehicles to which SAE J1395

applies are to made for the entire lamp and not for the individual compartments.

However, SAE J588 NOV84 continues to specify different minimum photometric requirements for one, two, and three "lighted sections". Because the SAE does not prescribe photometric requirements for more than three lighted sections, we have concluded that any device that contains more than three lighted sections need only comply with the requirements prescribed for three lighted sections.

I hope that this is responsive to your request.

ID: nht90-3.63

TYPE: INTERPRETATION-NHTSA

DATE: 08/22/90

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: JACK RADEMACHER -- CHIEF ENGINEER, POLAR TANK TRAILER, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 5-8-90 TO S. P. WOOD FROM J. RADEMACHER; (OCC 4776)

TEXT:

This is in reply to your letter of May 8, 1990, to Stephen P. Wood of this Office, asking for reconsideration of a recent interpretation of Standard No. 108.

We assume you mean our letter of January 9, 1990, to Howard Kossover of Oklahoma City. That interpretation stated that if rear lamps on a semi-trailer were mounted 27 inches forward of the rear edge of the vehicle, they were not mounted "on the rear", t he location specified by Standard No. 108. We also observed that compliance with the 45-degree visibility requirements in that location appeared questionable. You say that it has long been the practice of the Truck Trailer Manufacturers Association (TT MA) and its members that "if the 45 degree visibility requirement of these lights were met 'on the rear' of the trailer both inboard and outboard, the manufacturer met the intent of the standard." You inform us that the liquid bulk transport industry is especially affected by this interpretation because of reasons of practicality unique to tank transports. On these vehicles, you state that the rear lamps have been "mounted as far as 36 inches forward from the rear of the bumper", but that, in this loca tion, they "still maintain the 45 degree visibility requirements." You therefore ask for reconsideration of the interpretation if the 45 degree visibility requirements are met.

The lamps in your letter (and Mr. Kossover's) are stop, turn signal, and tail lamps. Only the tail lamps are presence lamps. The stop lamps and turn signal lamps operate independently of the headlamps. That is to say, they are intended for use at all times and not just at night or under other conditions of reduced visibility. They indicate actions taken by the vehicle operator to signal his operational intentions to other drivers and pedestrians. Problems with depth perception of following drivers could result if the lamps are not mounted "on the rear" as the standard requires. We are willing to interpret "on the rear" as meaning the trailing edge of the rear fender, which may not extend as far rearward as the bulk tank container, provided the vi sibility requirements are met, but we conclude that a mounting location for stop and turn signal lamps that is 36 inches forward from the rear of the bumper is not "on the rear" as the standard requires.

ID: nht90-3.64

TYPE: Interpretation-NHTSA

DATE: August 22, 1990

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

TO: Erika Z. Jones -- Chief Counsel, NHTSA

TITLE: Re FMVSS No. 108 (Lamps, reflective devices, and associated equipment) Procedure of Re-calibration for Replaceable Bulb Headlamp with VHAD

ATTACHMT: Attached to diagram entitled Re-Calibration Procedures in The Shops (graphics omitted); Also attached to letter dated 10-3-90 from P.J. Rice to M. Iwase (A36; Std. 108)

TEXT:

FMVSS No. 108 specifies in S7.7.5.2(a)(2)(iv) that the horizontal indicator of VHAD shall be capable of re-calibration over a movement of +-2.5 degrees.

We would like to confirm your interpretation concerning the method and procedures of re-calibration on the vehicle after repair from accident damage.

Enclosed please find a copy of Federal Register dated February 8, 1990 (Page 4425 and 4426), in which NHTSA interprets, as follows;

If the dimensional specifications of vehicle body and appropriate instruction are described in shop manual, re-calibration could be addressed.

However, we don't believe that the method mentioned in the NHTSA's interpretation is practicable, with the following reasons;

(1) There may be some case that linear measurement of distance will be unable to be taken between reference points on vehicle body and headlamp units, owing to interruption of some other parts in engine room.

(2) Even if possible to measure linearly, we are afraid that it will be difficult to measure it precisely.

Therefore we are going to adopt a method of addressing for re-calibration in which headlamp with it's lens being masked partially are lit and visually aimed with the help of photometric beam pattern on the screen. (see Fig. 1 and the enclosed pictures). Our experiment proved that the visually aiming by photometric beam pattern be practicable.

We are fully aware that this method needs some space of 3 meters or so between illuminated headlamps and the scren (see Fig. 2) for clear image of beam pattern, which is not necessarily possible to accomodate in every case.

Therefore we are preparing Shop Manual in which both methods of NHTSA's dimensional data and our proposing visual aiming by photometric beam pattern are prescribed, and presenting the optional alternative of the above two methods. We intend to provide a masking sheet for the visual aiming, with Shop Manual.

We would be greatly appreciate it if you would kindly advise us whether our proposal could go along with NHTSA's intention.

Thanking you for your kind and prompt reply, in advance, we remain, with best regard, yours very truly.

Attachment is entitled Re-Calibration Procedures in The Shops (graphics omitted).