Interpretation ID: nht89-3.20

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 18, 1989

FROM: M. IWASE -- GENERAL MANAGER, TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: VEHICLE HEADLAMP AIMING DEVICE (DOCKET NO. 85-15; NOTICE 8)

ATTACHMT: ATTACHED TO LETTER DATED APRIL 9, 1990 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED SEPTEMBER 12, 1988 TO M. IWASE FROM ERIKA Z. JONES AND LETTER DATED APRIL 8, 1988 TO ERIKA Z. JONES FROM M. IWASE. TEXT:

We would like to again ask your interpretation of FMVSS 108 concerning Vehicle Headlamp Aiming Device (VHAD).

In responding to our question dated April 8, 1988, you kindly gave us the interpretation dated September 12, 1988, for which thank you very much.

At that stage the provision of VHAD were just a proposal (Notice 5). On May 9, 1989, a final rule (Notice 8) of the VHAD has been issued.

Therefore, at this stage when the final rule has been issued, we would again ask and confirm your interpretation, as shown in the attached sheets.

Upon your kind review to the above matters, your prompt reply would be greatly appreciated.

Encl. Our previous letter of inquiry dated April 8, 1988 Your responding letter dated September 12, 1988.

ATTACHMENTS

BACKGROUND

In a letter dated April 8, 1988, we asked about a detachable spirit level which is installed in the socket by removing a bulb. In responding to our inquiry the agency stated in a letter dated September 12, 1988, as follows;

"----- Although the proposal does not specifically prohibit this feature, the test procedures do not anticipate a VHAD design where the light source would be removed and replaced with the VHAD."

On account of your advice we recently made some design modification on our detachable spirit level, as shown below: Detachable Spirit Level (Koito's New Design) [GRAPHICS OMITTED] 1) Detachable spirit level is mounted onto a headlamp housing. (Headlamp shall be aimed with bulb remaining in the socket.)

2) Once the headlamp is aimed, the spirit level would be remove to another (the other side) headlamp for aiming it. We are able to provide a single spirit level with each vehicle, which results in a significant cost saving.

QUESTION:

Could the above detachable spirit level be accepted to the requirements of S7.7.5.2 "On-vehicle aiming" in FMVSS No. 108 ?

KOITO'S VIEW:

We have carefully reviewed the wording of S7.7 "Aimability Performance", and found that the following provision is specified in S7.7.5.2(c)(1) - "Testing the VHAD";

"The headlamp assembly (the headlamp(s) and the integral or separate VHAD mechanism) shall be mounted on a level goniometer,

The above provision in the final rule (Notice 8) allows a detachable spirit level, we think.

Structure-2: Detachable Spirit Level [GRAPHICS OMITTED]

1) Spirit level is not permanently fixed onto headlamps.

2) Spirit level is built into bulb gauge.

3) When aiming adjusted, bulb is moved out and Bulb gauge is mounted into reflector socket.

4) Bulb gauge is provided for each vehicle as a standard part.