ID: nht90-3.16

TYPE: Interpretation-NHTSA

DATE: July 12, 1990

FROM: Michael L. Hayes

TO: James Gilkey -- NHTSA

TITLE: Re Non Compliance to Standard 213 in the Transport Incubator

ATTACHMT: Attached to letter dated 1-15-91 from Paul J. Rice to Michael L. Hayes (A37; Std. 213; FMVSS 102(4)); Also attached to letter dated 7-12-90 from Michael L. Hayes to General Curry

TEXT:

In our resent phone conversation regarding transport safety for the new born infant which is transported in incubators, I brought to your attention that the child restraint equipment used in this area does not meet Standard 213. I have enclosed a sales brochure to illustrate my point. It is anticipated that the companies involved will claim that, due to the special circumstances involved in this type of transport, Standard 213 cannot be met and, thus, is not applicable to transport incubators. In view of this objection, I have included a copy of an engineering analysis of a restraint technique showing a design that can meet Standard 213 and meet the special needs of this type of transport as well.

It is estimated that close to 100,000 infants are transported in this type of equipment each year. If only one half of one percent of these infants are injured due to the lack of proper protection, this represents hundreds of needless injuries and possi bly scores of deaths.

The companies involved are aware of the moldable air-bag restraint technique and its ability to vastly improve the safety of the infant. However, the belief that it would not be profitable "enough" to up grade the transport incubator with proper occupant protection has lead to the continued sales of substandard equipment. This equipment is designed and sold specifically as a "transport" incubator in that its principal purpose is the transport of the infant. It is clear that if this equipment is capabl e of meeting child transport safety standards through specifically designed occupant protection systems the compliance should be halted.

I would like to ask that you take up this project on behalf of the infant and enforce Standard 213 as it applies to "car bed" type restraints.

Attachment

Air-Shields Vickers sales brochure entitled TI-100 Infant Transport Incubator (Text omitted)

Attachment

An Engineering Analysis of a Developmental Transport Restraint System for the Neonate by Michael L. Hayes and Dr. Brent Coleman (Text and graphics omitted)

ID: nht90-3.17

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: Barry Felrice -- Associate Administrator for Rulemaking, NHTSA

TO: Brian Gill -- Senior Manager, Certification Department, American Honda Motor Co., Inc.

TITLE: None

ATTACHMT: Letter dated 3-16-90 to B. A. Kurtz from B. Gill with enclosure

TEXT:

This responds to your request that this agency determine that the new antitheft device proposed to be installed on the MY 1991 Honda Acura NS-X car line, represents a de minimis change in the system that was the basis for the agency's previous granting o f a theft exemption for the car line beginning in MY 1991, and that therefore the Acura NS-X vehicles containing the new device would be fully covered by that exemption.

As you are aware, the Acura NS-X car line was granted an exemption, pursuant to 49 CFR Part 543, from antitheft marking because Honda showed that the antitheft device to be used in lieu of marking on the car line was likely to be as effective as parts ma rking. This exemption was issued on February 5, 1990, and appeared in the Federal Register on February 9, 1990 (55 FR 4746).

The agency granted the exemption from theft marking because the agency found that based on substantial evidence, the agency believed that the antitheft device is "likely to be as effective in reducing and deterring motor vehicle theft as compliance with the parts-marking requirements of the theft prevention standard (49 CFR Part 541)." In the granting of the exemption from theft marking, the agency stated that it believed that the device will provide the types of performance listed in 49 CFR Part 543.6 (a)(3): Promoting activation; attracting attention to unauthorized entries; preventing defeat or circumventing of the device by unauthorized persons; preventing operation of the vehicle by unauthorized entrants; and ensuring the reliability and durabili ty of the device.

In your letter, it was stated that beginning from MY 1991, Honda plans improvements in the antitheft device that is standard equipment on the Acura NS-X in two ways: First, the new antitheft system would be armed by using the auto door lock system contr ol to lock either door. Honda states that in the system that was the subject of the exemption from the theft prevention system, it was necessary to use the control on the driver's door in order to arm the system. According to the attachment provided in your letter, this change would make it possible to arm the theft deterrent system by locking either door even if the other door is left unlocked. Second, the radio would now be included in the alarm system. Thus, the alarm system will be activated if the radio terminal or the coupler is disconnected, or if the radio's wiring is cut.

After reviewing the proposed changes to the componentry and performance of the antitheft device on which the exemption was based, the agency concludes that the changes are de minimis. While the new device has enhanced componentry and provides some aspec ts of performance not provided by the original device, it also continues to provide the same aspects of

performance provided by the original device and relies on essentially the same componentry to provide that performance. Therefore, it is not necessary for Honda to submit a petition to modify the exemption pursuant to 49 CFR Part 543.9(c)(2).

If Honda does not implement the new antitheft device as described in your letter, or delays implementation until after MY 1991, we request that Honda notify the agency of such decisions.

It is my understanding that, in a May 16, 1990, telephone conversation between Brian Tinkler of Honda and Dorothy Nakama of NHTSA's Office of Chief Counsel, Mr. Tinkler confirmed that Honda was not requesting confidential treatment of any information pro vided in your letter. Therefore, a copy of your letter, and this response, will be placed together in NHTSA's public docket.

ID: nht90-3.18

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: S. Watanabe -- General Manager, Automotive Equipment Technical Coordination Dept., Stanley Electric Co., Ltd.

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to S. Watanabe (A36; Std. 108)

TEXT:

We would like to ask you a question about a configuration of combination rear lamp which fulfils both tail and rear side marker functions as sketched below.

(Graphics omitted)

In accordance with the requirement of S.5.5.7 of FMVSS No. 108, the two functions (ie. Tail & Side marker) are presented at the same time. Thus the light output of side marker lamp is also emanated toward the rear of the vehicle mixed with tail lamp ligh t, and similarly, the light output of tail lamp is also emanated toward the side mixed with side marker lamp light.

Please let us have your answers to the following questions.

1) Should the Tail lamp function of this lamp meet the photometric requirements for 2 lighted sections, or 3 lighted sections?

2) Should the Side marker function of this lamp meet the photometric requirement of SAE J592e by 3 lighted sections or 1 lighted section?

I greatly appreciate receiving your reply to the above as soon as possible.

ID: nht90-3.19

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: J.P. Ravier -- R&D Director, Valeo; Guy Dorleans -- Regulatory Affairs Manager, Valeo

TO: P.J. Rice -- Chief Counsel, NHTSA

TITLE: Re Ref: 861 M 90

ATTACHMT: Attached to letter dated 12-13-90 to M.J.P. Ravier from Paul Jackson Rice (A36; Std. 108); Also attached to letter dated 7-30-90 to J.P. Ravier from Kathleen DeMeter

TEXT:

Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, " Lamps, Reflective Devices and Associated Equipmen t."

In its issue of May 9th 1989, the Federal Register Vol. 54 No 88 in paragraph S.7.7.5.2. allows the use of a Vehicle Headlamp Aiming Device for lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. Valeo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:

" Aiming concept for headlamps. Solution 2." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car.

We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.

After our demonstration of a working prototype to NHTSA personnel on June 29th, we would ask you to provide us with your confirmation of our interpretation of Standard 108.

Upon your kind review to this matter, your promptly reply would be greatly appreciated.

Enclosure

July 13th, 1990

Aiming concept for Headlamps. Solution 2. 1) Description of the headlamp.

The lamp is composed of a lens with no aiming pads, a housing bolted on the car body and a reflector which moves independently inside the housing. The lens has a clear area which allows to observe a bubble spirit level fixed on the reflector. This cyli nder has its axis parallel to the longitudinal axis of the vehicle.

The horizontal aiming feature consists in two combined coaxial screws and nut, hereafter referred to as AH and BH. The cap which gives access to the AH screw can be removed by using simple tools. The clearly legible outer surface of BH has graduations representing less than .38 degrees and a total amplitude of .76 degrees to the left and .76 degrees to the right.

2) Vertical reaim.

On the assembly lines of the lamp manufacturer, each lamp is individually aimed thanks to photometric means. The car manufacturer, on its assembly lines, also aims each lamp with photometric means. The position of the seating plane of the housing is ch ecked carefully, and each bubble vial is set to zero and then blocked for life in this position by the lamp manufacturer. To reaim vertically:

2 1) Check the car fulfills the specifications of SAE J 599 May '81. 2 2) Measure the longitudinal angular value of the floor slope. Note the figure and its orientation, positive or negative. 2 3) Operate the aiming control until the bubble has slid by an equal number of fiducial marks in the appropriate direction. 2 4) Do the same for both lamps.

3) Horizontal reaim.

On the assembly lines of the car manufacturer, provisions are taken so that the zero position of the BH nut coincides with the specified aim. To reaim horizontally: Rotate the BH nuts until their fiducial mark coincides with the zero of their body counterparts.

4) Vertical reaim after accident dammage.

This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor of their premices must be rigid, flat and substantially horizontal.

4 1) Rotate the vertical aiming control until the bubble comes to the zero position. If, after severe dammage, the bubble can not reach the origin of the scale because the stroke of the aiming screw is too small, place shims between the body panel and t he housing.

5) Horizontal reaim after accident dammage.

The remarks of the preceeding paragraph also apply.

5 1) Set to zero the fiducial mark on BH, right hand side. 5 2) Remove the bulb service bonnets, and attach the string aimer to the reflector, as shown on section AA of attached documents. No mispositionning can happen, because the aimer for t he left hand lamp cannot fit into the right hand lamp.

5 3) Unroll the string from its right hand reel and affix it to the opposite string aimer. 5 4) Tightly prevent the BH nut from rotating, remove the cap 5 5) Operate the right hand screw AH until the string comes to the zero of

the fiducial marking on the right hand aimer. 5 6) Symetrizing the instructions, do the same for the left hand lamp, remove aimers, reinstall the bonnets.

It is important to note that this example does not exclude the use of conventionnal means, like the aiming screen or even the more modern fractionnal balance aiming machines. Like for vertical reaim after dammage, shims may be necessary if the stroke of the AH screw does not suffice.

Attachments

Drawing of string aimer left hand unit solution 2. (Graphics omitted.)

Drawing of horizontal aiming feature solution 2. (Graphics omitted.)

ID: nht90-3.2

TYPE: Interpretation-NHTSA

DATE: June 28, 1990

FROM: Satoshi Nishibori -- Vice President, Industry-Government Affairs, Nissan Research & Development, Inc.; Signature by Kazuo Iwasaki

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-18-90 from P.J. Rice to S. Nishibori (A36; Std. 101)

TEXT:

This letter is to request NHTSA's interpretation of how the requirements of FMVSS 101 (Controls and Displays) would apply to two vehicle systems that Nissan is considering using. These systems are described below.

I. Car Phone

Nissan is considering offering a car phone for use in certain of its passenger cars. The car phone would be installed in the vehicle's console, in the lower, forward portion of the driver's field of vision. The car phone would have five visual displays, each of which is bright enough to be seen under all ambient lighting conditions. The illumination for these displays is not variable and the system may not be turned off while the vehicle ignition switch is in the "ON" position.

The first display shows the number that is being dialed (see Figure) through an LED. This display is illuminated whether or not the telephone is in use, and the number being dialed is shown during the time that the phone is in use.

The second display illuminates the push buttons for dialing numbers. This display is illuminated when the first button is pushed when dialing a number, and the display remains illuminated for a period of ten seconds.

Finally, the system uses three LED indicators. The first indicator (IU) is illuminated when the phone is "in use." The second indicator (NS) is illuminated when the system is outside an area where cellular phone service is available (i.e., "no service" ), as determined by the failure of the system's "roaming" function to lock on an available phone line. The third indicator (RM) is illuminated when this "roaming" function is operating, when outside the system's local operating area.

It is our understanding that this phone system would comply with FMVSS 101 requirements if the five information displays are considered to be "telltales." The term "telltale" is defined in section 4 of FMVSS 101 as "a display that indicates the actuatio n of a device, a correct or defective functioning or condition, or a failure to function." Since the displays used in the phone system indicate operation of various functions of the phone system, the displays may meet the definition of "telltale" in sec tion 4 of the standard. If so, the system would appear to be consistent with the requirement for telltales in section 5.3.4(a) of FMVSS 101, since the illumination of the displays is bright enough to be visible under all ambient lighting conditions. On the other hand, the system would not appear to meet the requirements of section 5.3.5 of the standard

if the displays are considered to be other "sources of illumination," since the displays do not have variable illumination, are brighter than "barely discernible" in night conditions, and may not be turned off without shutting off the vehicle.

Please inform us whether the displays used in this car phone system are "telltales" or other "sources of illumination," and whether the system is consistent with the requirements of FMVSS 101.

II. Air-conditioning Indicator Light

In certain vehicles, Nissan uses an indicator light that is illuminated whenever the air-conditioning system operating switch and the ignition switch are in the "ON" position. When the air conditioner or the ignition switch is turned "OFF," the indicato r light is extinguished.

Nissan believes that the air conditioner indicator qualifies as a "telltale," since it indicates the "actuation of a device." If the air conditioner indicator display is considered to be a "telltale," it would appear to meet the requirements of section 5.3.4, since the display is bright enough to be visible in all ambient lighting conditions.

On the other hand, this display would appear to be comparable to the radio display that is described in NHTSA's January 7, 1988, letter to Isuzu. In that letter, the Agency concluded that the illuminated radio display is considered to be one of the other "sources of illumination" in section 5.3.5 of FMVSS 101. Since the radio display can be turned off by turning off the radio, NHTSA considered it to be consistent with section 5.3.5(3). In the same manner, the air conditioner indicator display can be tu rned off by shutting off the air conditioner system. The radio display referred to in the Isuzu interpretation would also seem to meet the "telltale" definition, although the radio display serves the function of aiding tuning of the radio in addition to indicating whether the device is operating.

Please inform us as to whether the proposed air conditioner lighting display is considered to be a "telltale" or an "other source of illumination" under section 5.3.5 of the standard, and whether the display would be consistent with applicable requiremen ts.

If you require further clarification regarding the proposed Nissan systems, please contact Mr. Kazuo Iwasaki of my staff at 202/466-5284.

(Drawing attached).

ID: nht90-3.20

TYPE: Interpretation-NHTSA

DATE: July 16, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc. TITLE: None

ATTACHMT: Letter dated 2-27-90 to Stephen Wood from Delbert N. Pier; (OCC-4526) TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 107, Reflecting Surfaces. (49 CFR 571.107). I apologize for the delay in our response.

You explained that Hyundai is planning to test the surface of a windshield wiper blade rail spring by using several rail springs gathered together because one spring would have a limited amount of area to reflect the light source. You asked the National Highway Traffic Safety Administration (NHTSA) to confirm your view that this method of compliance testing is a satisfactory method of complying with section S4 of Standard No. 107.

By way of background information, NHTSA has no authority to approve, endorse or offer assurances of compliance for any motor vehicle or item of motor vehicle equipment. Instead, the National Traffic and Motor Vehicle Safety Act of 1966 ("Vehicle Safety Act") makes manufacturers of motor vehicles or items of motor vehicle equipment responsible for certifying that each of its products conforms with all applicable safety standards. The following represents our opinion based on the facts provided in your l etter.

Each safety standard specifies performance requirements and test procedures used by the agency in its compliance testing to evaluate a vehicle or item of equipment. For instance, section S4 of Standard No. 107 specifies specular gloss requirements for c ertain vehicle components, including windshield wiper arms and blades. That provision requires that the specular gloss of the specified components must not exceed 40 units when measured by the 20 degree method of ASTM Standard D523-62T.

While the agency would follow ASTM Standard D523-62T for purposes of compliance testing, the Vehicle Safety Act does not require a manufacturer to test its products in the manner specified in a motor vehicle safety standard or even to test the product 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 that standard, provided, however, that the manufacturer exercises due care in ensuring that the vehicle or equipment will comply with Federal requirements when tested by the agency according to the procedures specified in the standard. In other words, the manufacturer must show that its chosen means of evaluating compliance is a reasonable surroga te for the test procedure specified by the standard.

In the event that the agency determines an apparent noncompliance exists with a vehicle or item of equipment tested in the agency's compliance program, the manufacturer must show the basis for its certification that the vehicle or equipment complies. Th e manufacturer may be subject to civil penalties unless it can establish that it exercised due care in its designing and manufacturing of the product and in its checking (through actual testing, computer simulation or otherwise) to ensure compliance, but nevertheless did not have reason to know that the vehicle or item of equipment did not in fact comply. Of course, notwithstanding the exercise of due care, the manufacturer would still be subject to the recall responsibilities of the Vehicle Safety Act for any noncomplying vehicles or equipment.

With these considerations in mind, you appear, based on the statements in your letter, merely to be testing a group of identical components with identical specular gloss levels at one time rather than separately. If this is the case, it appears that you r intended method of testing is consistent with the testing procedures in Standard No. 107.

I hope this informaiton answers your questions. Please contact Mr. Marvin Shaw of my staff at (202) 366-2992, if you have further questions.

ID: nht90-3.21

TYPE: Interpretation-NHTSA

DATE: July 18, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Michael O'Donnell

TITLE: None

ATTACHMT: Letter dated 4-18-90 to Chief Counsel's Office, NHTSA from Michael O'Donnell; (OCC 4690) TEXT:

This is in response to your letter to this office asking whether NHTSA's safety standards apply to vehicles in service on the public roads. Specifically, you were interested in the applicability of NHTSA requirements to a 1977 school bus that was convert ed to a "recreational vehicle/house coach" that is now only for personal and family use.

The Federal Motor Vehicle Safety Standards (FMVSS) promulgated by this agency apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. The requirement that a motor vehicle or item of motor vehicle equipment compl y with all applicable FMVSS applies only until the product is first sold to a consumer. Both before and after a vehicle or item of equipment is first sold to a consumer, any modifications to that product are affected by section 108(a)(2)(A) of the Natio nal Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), which states:

No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in co mpliance with an applicable Federal motor vehicle safety standard . . . .

If any of the commercial entities identified in section 108(a)(2)(A) were to make modifications that resulted in a "render inoperative" violation, the violating commercial entity would be liable for a civil penalty of up to $1,000 for each violation. Pl ease note that this "render inoperative" provision does not apply to a vehicle owner. The vehicle owner may modify his or her vehicle without violating any Federal requirements, irrespective of whether the modification affects the vehicle's compliance w ith a safety standard.

Please note also that the individual States have the authority to regulate the operation and use of motor vehicles within their borders.

Additionally, the individual States have the authority to regulate the modifications that may be made to a vehicle by its owner. You may wish to contact the Department of Motor Vehicles for the State of New York to learn if the State has established any requirements applicable to your use or registration of this vehicle in New York.

I hope you have found this information helpful.

ID: nht90-3.22

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: T. Spingler, Robert Bosch, GmbH

TO: Rich v. Iderstine -- Office of Rulemaking, NHTSA

TITLE: FMVSS 108, S.3. Definitions

ATTACHMT: Attached to letter dated 8-2-90 to T. Spingler from P. J. Rice; (A35; Std. 108)

TEXT:

Five weeks ago (06/14/90) I discussed the word "bonded lens" with Larry Ayers, ETL, regarding headlamps with movable reflector and "VHAD". Usually we in Europe use rubber-seal and clips to fix the lens to the housing. To meet the requirements of FMVSS 108, Larry proposed to fix the lens of those headlamps by adding e.g. silicone-glue at four places between lens and housing to prevent the removal of the lens. Jerry Medlin, whom we called that day, agreed to that interpretation. To get an official int erpretation, I ask you to write me a letter regarding this "problem".

ID: nht90-3.23

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Susan Birenbaum -- Acting General Counsel, United States Consumer Product Safety Commission

TITLE: None

ATTACHMT: Letter dated 10-26-89 to S. Wood from S. Birenbaum; (OCC 4092); and photos (text omitted); and undated Consumer Product Incident Report for D.Jaeger

TEXT:

This responds to your letter asking whether a product would be considered an item of "motor vehicle equipment," within the meaning of the National Traffic and Motor Vehicle Safety Act (the Safety Act). I apologize for the delay in this response. The pr oduct in question is called "kwik kool" and is intended to improve the performance of motor vehicles' air conditioning systems. The packaging and labeling for this product that were enclosed with your letter indicate that "kwik kool" is intended exclusi vely for use with a motor vehicle and by ordinary users of motor vehicles. We conclude that this product is "motor vehicle equipment."

As you are aware, section 102(4) of the Safety Act, 15 U.S.C. 1391(4), defines, in relevant part, the term "motor vehicle equipment" as:

any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle . . .

"Kwik kool" is an aerosol component that appears to be manufactured and sold for the improvement of motor vehicle air conditioning systems. As such, it is "motor vehicle equipment" within the meaning of the Safety Act.

You noted in your letter that the Consumer Product Safety Act excludes items of "motor vehicle equipment" from those "consumer products" subject to the authority of the Consumer Product Safety Commission under that Act. This agency, on the other hand, ha s express statutory authority to investigate allegations that an item of motor vehicle equipment contains a defect related to motor vehicle safety. Pursuant to the request in your letter, we have forwarded the complaint enclosed with your letter to our Office of Defects Investigation.

If you have any questions or would like some additional information about this topic, please feel free to contact Mr. Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht90-3.24

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: Guy Dorleans -- Manager, Regulatory Affairs Department Division Eclairage-France

TO: P. J. Rice -- Chief Counsel, NHTSA

TITLE: Ref: gd 862 M90

ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-12-90 from P.J. Rice to M.G. Dorleans (A36; Std. 108)

TEXT:

Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108," Lamps, Reflective Devices and Associated Equipment ."

In its edition of May 9th 1989, the Federal Register Vol. 54 N 88 allows the use of lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. V aleo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:

"Aiming concept for headlamps. Solution 3." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car. These instructions will emphasize on the nov elty in using SAE J602 headlamp external aimers.

We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.

We would ask you to provide us with your confirmation of our interpretation of the Standard 108 in this matter. We are ready to demonstrate NHTSA a working prototype if you deem it necessary.

Upon your kind review to this matter, your promptly reply would be greatly appreciated.

Enclosure

July 19th, 1990

Aiming concept for headlamps. Solution 3. 1) Description of the headlamp.

The lens has 3 aiming pads on which can be attached a mechanical aiming device as per SAE J602 Oct 80. The housing contains a movable reflector, a horizontal aiming feature and a vertical aiming feature. These parts and the fixed point are designed so that there is no possibility to modify

the horizontal aim when aiming vertically, and vice versa.

The vertical aiming feature consists in two combined coaxial screw and nut, hereafter referred to as AV and BV:

AV is used on the assembly lines of the lamp manufacturer and also on the assembly lines of the car manufacturer. While the aiming plane is placed in its designed position, the low beam is photometrically aimed and the fiducial mark of BV is set to zero . The rotation of AV achieves this initial aim, while BV can not move. Then the cap is inserted. This cap can not be removed using simple tools. The repair shops and the dealers have the necessary equipment to remove the cap. AV is also the aiming f eature which must be used to repair the vehicle after accident damage.

BH is the aiming nut which must be used during normal reaim operations

The horizontal aiming feature is so designed that when a torque is applied to BV, AV rotates with the same angle. In other terms, the friction torque between BV and AV is far bigger than the friction torque between AV and the housing.

The horizontal aiming feature, consisting of a screw AH and a nut BH, uses basically the same principle as its vertical counterpart.

Both vertical and horizontal reaim features are permanently attached to the headlamp.

2) Vertical reaim.

A commonly available mechanical aimer must be used. This kind of aimer has been used in the US since the early '50s, and are available in each repair shop or dealers. Among them, the Hopkins B4A is a good example of easy-to-use external aimer, with aer odynamic headlamps capability thanks to its articulated vacuum cup and universal extender.

The ground surface must be substentially flat. The car must fulfill the requirements of SAE J 599 May '81.

2 1) Set to zero the fiducial mark on BV

2 2) Attach calibration fixtures to the aimers, place aimers at the centerline of each wheel on one side of the vehicle. Level each unit by adjusting screw on each calibration fixture.

2 3) Transfer the reading indicated on the horizontal dial to the floor level dial on each aimer. Set the "vertical" dial of each aimer at zero.

2 4) Remove calibration fixture

2 5) Check that universal extenders are set to the values engraved on the lens, and attach each mechanical aimer to its designated lamp. Check the sight openings face each other.

2 6) Rotate the "vertical" dial of each aimer intil the bubble is centered

in the vial. Tranfer to BV the value the "vertical" dials indicate for each side of the car.

3) Horizontal reaim.

3 1) The horizontal dials and the BH nuts must be set to zero.

3 2) Rotate each "horizontal" dials until the the split image of each aimer are aligned.

3 3) Respective of the side, transfer the readings of the aimers to the BH nuts.

4) After accident damage.

This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor must be rigid, flat and horizontal The special tools allow to remove the cap, thus giving access to the A H and AV screws. The BH and BV nuts being securely maintained in zero position, the operator:

4 1) Checks the angles of the aiming plane 4 2) Uses a screen at 7.6 m, or a fractional balance aiming machine, or a pair of string aimers.

Guy Dorleans Valeo Lighting.

Enclosure: 1

(Drawing attached, graphics omitted)