Interpretation ID: 1984-3.32

TYPE: INTERPRETATION-NHTSA

DATE: 10/19/84

FROM: ROGER HAGIE -- KAWASAKI MOTORS CORP USA

TO: OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: REQUEST FOR INTERPRETATION...FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 01/02/85 FROM FRANK BERNDT -- NHTSA TO ROGER HAGIE, REDBOOK A26, STANDARD 108

TEXT: Dear Sir:

Kawasaki Motors Corp., U.S.A. requests an interpretation of the provisions of FMVSS 108 with respect to a new headlamp design/concept under development at Kawasaki.

We are aware of the interpretation issued by your office to Koito Manufacturing Co. (letter dated July 24, 1984) in response to their request of June 21, 1984. In this interpretation, you confirmed that two headlamps, each meeting the requirements of SAE J584 may be used on a motorcycle when mounted side-by-side as described by Koito's letter.

Kawasaki wishes to clarify a question which we feel was raised by the Koito request and your response, and to further determine your position with respect to our design ideas. Concerning the Koito request, Koito stated that their "headlamp unit is optically designed to be less than 75,000 cd". It is unclear to us whether Koito was referring to the output of a single lamp in their dual-lamp system, or whether the maximum output of both lamps together would not exceed 75,000 cd. Therefore, our first question is: Does the 75,000 limit (as specified by SAE J584) apply to each lamp individually, or must the total output of both lamps be limited to 75,000 cd?

Kawasaki is considering a headlamp design that consists of two reflectors, each with its own dual-filament bulb, and each capable of independent aim, installed in a single housing, and behind a single lens. Bulbs would be a standardized, replaceable unit, accessible from the rear of the housing. The assembly would meet all of the environmental and other requirements of SAE J584 and FMVSS 108. In some respects, this unit would be similar to the headlamp design proposed by Ford and approved by NHTSA on May 20, 1983. Our questions with respect to this design are: First, is such a design acceptable for a motorcycle? Secondly, would both reflectors have to be independently aimable, or could the aiming be accomplished by moving the whole lamp assembly as long as the aiming requirements of SAE J566 and the photometric requirements of SAE J584 are met?

Kawasaki would appreciate your earliest response to these questions. Please contact the undersigned if there are any questions or if any additional information is required.

Thank you for your attention to this matter.

Sincerely,