Interpretation ID: nht87-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 12/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase, Manager, Technical Administration Dept. Koito Mfg. Co., Ltd.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 7/23/87 letter from Erika Z. Jones to M. Iwase (Std. 108)

TEXT:

Mr. M. Iwase, Manager Technical Administration Dept. Koito Mfg. co., Ltd. Shizuoka Works 500, Kitawaki Shimuzu-shi, Shizuoka-ken JAPAN

This is in reply to your letter of September 15, 1987, with further reference to features of a 60 degree slant replaceable bulb headlamp presently being developed by Koito. You have explained that the aiming pads for the new system will be installed on t he aiming adapter, rather than the headlamp lens, and have asked for confirmation that this is "not illegal" under Motor Vehicle Safety Standard No. 108.

As you noted in your letter, paragraph S4.1.1.36(a) (2) specifically requires the exterior face of each replaceable bulb headlamp lens to have three aiming pads. The agency has no specifications for the design of aiming adapters, and a headlamp without a iming pads would be one that is not designed to conform to the standard.

The agency is examining concepts for aiming methods for other than mechanical aim, but no amendments to Standard No. 108 are contemplated that would permit or require aiming pads to be on aiming adapters.

Sincerely, Erika Z. Jones Chief Counsel

Air-Mail Ms. Erica Z. Jones Chief Counsel National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. E. Z. Jones:

We would like to further ask you the following question of headlamp aiming adaptor in connection with your kind advice mentioned in your letter of July 23, l987 replying to our letter of March 24, l987. (Refer to the attached.)

RE = 1 ) Aiming Adaptor for 60 " Slant Bulb Replaceable Headlamp

As shown below, instead of being installed, on the lens of headlamps, aiming bosses are installed on the surface of the special adaptor which is to be equipped onto each vehicle so that mechanical aiming can be performed, by use of the headlamp aimer " s pecified SAE J602C.

Of course, the special adaptor is so designed that it can be surely attached onto the proper design position of headlamps.

The aiming bosses and markings, which are applied to 54. 1. 1.36 (a) (2)& (3) of FMVSS No. 108, are placed on the surface of the special adaptor.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 2 / 3

Question:

We believe that the aiming boss installation as abovementioned can be applied to FMVSS NO. 108 and not illegal under FMVSS NO. 108. We would like you to confirm whether our interpretation is correct or not.

Aiming pads are specified in 54.1. 1.36 (a) (2) of FMVSS NO. 108 as follows;

"The exterior face of each replaceable bulb headlamp lens shall have three pads which meet the requirements of Figure 4, Dimensional Specifications for Location of Aiming Pads on Replaceable Bulb Headlamp Units .. ."

However, for all this prescription, we can not find it necessary that aiming pads shall be placed on the lens of headlamps which can be aimed by the use of the adaptor equipped onto each vehicle, because the special adaptor can be designed regardless of lens bosses so as to be surely attached onto the proper design position of headlamps in any way, we think.

And it is not only useless but also impractical that the specified aiming bosses are placed onto the lens of headlamps which slant up to about 60o in vertical and horizontal, because the projection of the aiming bosses becomes higher according to the len s slant inevitably.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 3 / 3

Upon our consideration of the abovementioned matter, it should not be required that aiming bosses shall be placed on the lens of headlamps which are aimed by use of the special adaptor equipped onto each vehicle.

Upon your review, your prompt reply to this matter would be greatly appreciated.

Very truly yours, M. Iwase Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works

See 7/23/87 letter from Erika Z. Jones to M. Iwase.