Interpretation ID: 19089.ztv

Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636, Japan

Re: Headlamp Lens Coating

Dear Mr. Suzuki:

This is in reply to your letter of November 5, 1998, asking for an interpretation of S5.1.2 of Federal Motor Vehicle Safety Standard No. 108.

According to your letter, Stanley Electric Co. has developed a new coating to "be applied to the inner surface of the headlamp lens for the purpose of" preventing frost. You relate that "the lens with its original coating applied to the outer surface" complies with Standard No. 108 after the 3-year outdoor exposure test of S5.1.2(b). The application of the inner coating "will not cause any change in the conformity of the original lens with its outer surface coating." For this reason, you believe that no further testing is required after application of the inner coating, and you ask whether your interpretation is correct.

Standard No. 108 does not require headlamp lenses to be coated on either the outer or inner surface. However, some manufacturers of headlamps with plastic lenses coat the outer surface of the lens as a means of ensuring that the plastic materials used in the lens meets the requirements of SAE Recommended Practice J576 JUL91, incorporated by reference in S5.1.2, and the requirements of S7.4(h) of Standard No. 108.

We cannot answer your question. Stanley must ensure that its headlamps as manufactured conform with all requirements of Standard No. 108. It is Stanley's responsibility in certifying compliance of the headlamp with all applicable standards within

Standard No. 108 to determine whether a coating on the inner surface of the plastic lens would result in a noncompliance of the plastic materials with S5.1.2 after a 3-year exposure test, whether or not Stanley conducts an actual test. Further, Stanley must ensure that the presence of the inner coating does not affect the ability of the headlamp to meet all the requirements that apply to it.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.12/22/98