Interpretation ID: aiam3858
Manager
Technical Administration Department
Koito Mfg. Co.
Ltd.
Shizuoka Works
500
Kitawaki
Shimuzu-shi
Shitzuoka-ken
Japan;
Dear Mr. Iwase: This is in reply to your letter of June 21, 1984, to Mr. Driver of thi agency asking for an interpretation of Motor Vehicle Safety Standard No. 108. Mr. Driver has not been an official of this agency for many years, and in the future, your request for interpretation should be addressed to the Chief Counsel, National Highway Traffic Safety Administration.; Your first question is whether Safety Standard No. 108 permits two-headlamp system on motorcycles. The answer is yes. Paragraph S4.1.1.34 specifies the lighting systems permissible on motorcycles. It allows two Type 2D1 or Type 2 (7 in.), or two Type 2B1 or Type 2B headlamps. Under Table IV, if two headlamps are used, they must be disposed symmetrically around the vertical center line. Two non-sealed headlamps meeting the requirements of SAE J584 may also be used, subject to the same mounting restriction. Therefore the system you propose appears acceptable under Standard No. 108.; You have also asked whether the two headlamps may be mounted one ato the other, rather than side by side. While Table IV specifies that a single headlamp must be mounted 'on the vertical centerline', it requires that two headlamps be disposed symmetrically around it. We do not interpret this language as allowing two headlamps to be mounted adjacent to each other on the vertical centerline.; Sincerely, Frank Berndt, Chief Counsel