Interpretation ID: aiam3696
Engineering Manager
Sylvania GTE Products Corporation
1231 'A' Avenue North
Seymour
IN 47274;
Dear Mr. Alexander: This is in reply to your letter of April 8, 1983, following conversation with Mr. Vinson of this office, with reference to Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; You are concerned with the 'design to conform' language as it relate to headlamps, and have asked for an interpretation that it 'does not mean that every lamp produced is required to have every photometric point in.'; I am not certain what you mean by 'every photometric point in' However, a manufacturer is expected to design his headlamps so that each will meet the minimum photometric output in candela set forth by SAE J579C for each test point. The agency does not pursue random occasional photometric failures at individual test points. But if a manufacturer's products show a pattern of failures to meet the minimum at any individual test point, the agency could consider this as an indication that the headlamp was, in fact, not 'designed to conform'.; I hope this answers your question. Sincerely, Frank Berndt, Chief Counsel