Interpretation ID: 1984-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 10/29/84

FROM: FRED W. BOWDITCH -- MVMA TECHNICAL AFFAIRS DIVISION

TO: DIANE K. STEED -- ADMINISTRATOR NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/14/85 EST, FROM BARRY FELRICE TO FRED W. BOWDITCH, REDBOOK A27, STANDARD 108

TEXT: Dear Miss Steed:

The Motor Vehicle Manufacturers Association of the United States, Inc. (MVMA) * files this petition under 49 CFR Part 552 requesting amendment of Federal Motor Vehicle Safety Standard No. 108.

* MVMA members are AM General Corporation, American Motors Corporation, Chrysler Corporation, Ford Motor Company, General Motors Corporation, International Harvester Company, M.A.N. Truck and Bus Corporation, PACCAR Inc., Volkswagen of America, Inc. and Volvo North America Corporation.

MVMA requests removal from section 4.1.1.36(a)(2) of the limitation requiring the three aiming pads to be located on the exterior face of the headlamp lens. So long as the aiming pads are accessible to the adjustable legs of the aimer locating plates described in Figure 9, there is no motor vehicle safety need to limit pad placement to the face of the lens. Adoption of this requested amendment would remove an unwarranted design restriction. By allowing the aiming pads to be located on a part of the headlamp other than the lens, e.g., the mounting flange at the lens-reflector joint, such amendment would facilitate, for example, the design of lower profile replaceable bulb headlamps. Use of such headlamps could enhance the aerodynamic properties of future vehicle designs. Accordingly, we request substitution of the following text for the current section 4.1.1.36(a)(2):

"S4.1.1.36(a)(2) Each replaceable bulb headlamp shall have three pads on the front surface of the lamp which form an aiming plane for mechanically adjusting and inspecting headlamp aim. In the front view of the lamp taken in a plane perpendicular to the longitudinal axis of the vehicle, the three pads shall be positioned to match corresponding locations, for either Group I or Group II, that are specified in Figure 9 (front view) for the adjustable legs of the locating plate. The pads shall be designed to permit use of a mechanical aimer conforming to SAE Standard J602 October 1980 "Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units", together with an adjustable locating plate described in Figure 9, to check the aim of the Headlamp. Group I aiming pad locations are those prescribed for the 2B1 sealed beam headlamp unit and Group II aiming pad locations are those prescribed for 1A1/2A1 sealed beam headlamp units. Each lens face shall have molded into it the settings, appropriate for that headlamp, of the lengths of the three legs of the adjustable locating plate. Each setting is to be located adjacent to the aiming pad to which it applies. The molded characters specifying the settings shall have a minimum height of 4mm".

If you would like to discuss this petition further, please call on us.

Very truly yours,