Interpretation ID: nht89-2.64

TYPE: INTERPRETATION-NHTSA

DATE: 08/09/89

FROM: KARL HEINZFABER -- MERCEDES BENZ OF NORTH AMERICA INC

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: REQUEST FOR INTERPRETATION, FMVSS 108, LAMPS, REFLECTIVE DEVICES AND ASSOCIATED EQUIPMENT

ATTACHMT: ATTACHED TO LETTER DATED 11/01/89 FROM STEPHEN P. WOOD -- NHTSA TO KARLHEINZ FABER -- MERCEDES BENZ OF NORTH AMERICA; REDBOOK A34; STANDARD 108

TEXT: Dear Mr. Wood:

Mercedes-Benz of North America, Inc. (MBNA) requests an interpretation of the word "headlamp" as used in Standard 108.

Paragraph S7.2 of the Final Rule published in the Federal Register of May 9, 1989 (Docket No. 85-15, Notice 8), states that each headlamp or beam contributor must be marked with its voltage. The term headlamp is not defined separately under S4 definitio ns, however, a "replaceable bulb headlamp" is defined as a "headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sources." Based on the definition of "replaceable bulb headlamp", it is our understanding t hat marking the lens, the reflector, or the light source with the voltage would be in compliance with paragraph S7.2.

We would appreciate your response at your earliest opportunity as the effective date of this marking requirement is December 1, 1989.

Should you have any additional questions, please feel free to contact Toivo Raabis at (201) 573-2624 in our Safety Engineering Department.

Thank you in advance for your reply.

Sincerely,