Interpretation ID: nht76-2.35

DATE: 06/02/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 20, 1976, asking for an amendment of S4.1.1.21 of Motor Vehicle Safety Standard No. 108 to allow a plus tolerance of 7.5 percent on maximum wattage requirements for Type 1A and 2A headlamps.

I enclose a copy of an interpretation furnished the General Electric Company which states that such a tolerance is allowed. However, to clarify our intent we plan to amend Standard No. 108 in the near future in the manner that you suggest.

YOURS TRULY,

STANLEY ELECTRIC CO., LTD.

April 20, 1976

Att.: E. T. Driver Director, Office of Crash Avoidance Motor Vehicle Programs

U.S. Department of Transportation National Highway Traffic Safety Administration

In item (c) of S4.1.1.33, FMVSS No.108 (41F.R. 1483 - January 8, 1976), a tolerance of +7.5% is allowed to the maximum wattage of each circular unit of automotive headlamps.

On the other hand, in item (b) of S4.1.1.21, FMVSS No.108 (40F.R. 54426 - November 24, 1975), such tolerance is not clearly specified for rectangular units.

From the table 3, SAE J573f, however, in case of these rectangular units, we noted, by calculation based on the maximum amperages specified there, that almost the same tolerances are allowed to the maximum wattages as those allowed by S4.1.1.33, FMVSS No.108.

Therefore, we would like to interprete the provision regarding the maximum wattages of rectangular units as that the same tolerance of +7.5% is also being allowed by you. Your comments on this matter is requested.

Furthermore, if such interpretation is not accepted by you, we ask you to amend the provision of S4.1.1.21 so that the same tolerance of +7.5% which is now being allowed for circular units may also be allowed to the maximum wattages of type 1A and type 2A rectangular units.

Thanking you in advance for your cooperation,

T. Takeda Manager, Automotive Lighting Engineering Dept.