Interpretation ID: nht89-2.9

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: H. HASEGAWA -- AUTOMOTIVE LIGHTING ENGINEERING CONTROL SECTION STANLEY ELECTRIC CO. LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 05/22/89 FROM H. HASEGAWA TO RICHARD L. VANIDERSTINE, RE REVISION OF FMVSS NO 108 [DOCKET NO 85-15 NOTICE 8

TEXT: Dear Mr. Hasegawa:

This is in reply to your FAX letter of May 22, 1989, to Richard Van Iderstine of this agency.

You have two questions with respect to the amendment to Standard No. 108 published on May 9, 1989 (Docket No. 85-15; Notice 8).

Your first question is the effective date of paragraph S7.7.5.1.(a), which you point out was not previously a requirement of Standard No. 108. You suggest the need for a delayed effective date (but give no reason why one may be needed).

Paragraph S7.7.5.1(a) will be effective June 8, 1989. Although the requirement is a new one (the restriction on motion of a headlamp when an external aiming device is applied to it), it was proposed as part of the December 29, 1987 NPRM, and no comments received indicated a need for a delayed effective date. Your supposition is correct; S7.5.5.1 will apply to all headlamps with an external aiming system, including those incorporating replaceable bulbs.

Your second question relates to paragraph S7.7.5.1(b), and you ask "whether the requirement of '0.1 in. max.' will be determined, either during the test or after the test". In pertinent part, subsection (b) states "nor shall the lamp recede more than 0. 1 in. (2.5 mm) after being subjected to an inward force...." This means that the measurement is determined after the test.

Sincerely,