Interpretation ID: aiam2596
Staff Assistant (Technical)
Lucas Industries North America
Inc.
Two Northfield Plaza
Troy
MI 48084;
Dear Mr. Gough: This is in reply to your letter of May 13, 1977, to the Administrato asking whether the circuitry diagram that you enclosed would allow compliance with S4.5.2 of Federal Motor Vehicle Safety Standard No. 108.; Paragraph S4.5.2 requires that 'each vehicle shall have a means fo indicating to the driver when the upper beams of the headlamps are on that conforms to SAE Recommended Practice J564a, April 1964 ....' Your diagram appears to meet the specifications of J564a allowing compliance of the system with S4.5.2 when installed in a motor vehicle. The entity legally responsible for compliance with S4.5.2, of course, is the vehicle manufacturer who must certify that its products meet all applicable Federal motor vehicle safety standards.; Yours truly, Joseph J. Levin, Jr., Chief Counsel