Interpretation ID: 19222.ztv

Mr. Edward L. Patterson, Sr.
Operations Manager
Gilbar Testing Laboratories, Inc.
6570 19 Mile Road
Sterling Heights, MI 48314

Dear Mr. Patterson:

We are replying to your letter of November 24, 1998, to Taylor Vinson of this Office, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.

S7.8.2 of Standard No. 108 allows the installation of protective covers for headlamp aiming adjusters, "removable without the use of tools." You wish to manufacture a design to provide a locking feature. The design "would require only a slight rotating movement to lock." You "propose placing an indentation or hole in the cover, which would allow either a `key' or `coin' be used in order to accomplish this movement." You ask whether "the use of a coin or key, as proposed, be in violation."

The use of a key or coin to complete the locking movement would not result in a noncompliance with S7.8.2, but your letter implies that their use is also required for the cover to be removed. As we informed Ford Motor Company on February 12, 1998 (copy of letter enclosed), we consider an ignition key to be a "tool." If a tool is needed to remove a protective cover, then S7.8.2 has not been met. Similarly, we would consider a coin to be a "tool" when used for the purpose of removing the cover.

If you have any questions, you may phone Taylor Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d.2/17/99