Interpretation ID: nht90-3.19
TYPE: Interpretation-NHTSA
DATE: July 13, 1990
FROM: J.P. Ravier -- R&D Director, Valeo; Guy Dorleans -- Regulatory Affairs Manager, Valeo
TO: P.J. Rice -- Chief Counsel, NHTSA
TITLE: Re Ref: 861 M 90
ATTACHMT: Attached to letter dated 12-13-90 to M.J.P. Ravier from Paul Jackson Rice (A36; Std. 108); Also attached to letter dated 7-30-90 to J.P. Ravier from Kathleen DeMeter
TEXT:
Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, " Lamps, Reflective Devices and Associated Equipmen t."
In its issue of May 9th 1989, the Federal Register Vol. 54 No 88 in paragraph S.7.7.5.2. allows the use of a Vehicle Headlamp Aiming Device for lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. Valeo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:
" Aiming concept for headlamps. Solution 2." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car.
We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.
After our demonstration of a working prototype to NHTSA personnel on June 29th, we would ask you to provide us with your confirmation of our interpretation of Standard 108.
Upon your kind review to this matter, your promptly reply would be greatly appreciated.
Enclosure
July 13th, 1990
Aiming concept for Headlamps. Solution 2. 1) Description of the headlamp.
The lamp is composed of a lens with no aiming pads, a housing bolted on the car body and a reflector which moves independently inside the housing. The lens has a clear area which allows to observe a bubble spirit level fixed on the reflector. This cyli nder has its axis parallel to the longitudinal axis of the vehicle.
The horizontal aiming feature consists in two combined coaxial screws and nut, hereafter referred to as AH and BH. The cap which gives access to the AH screw can be removed by using simple tools. The clearly legible outer surface of BH has graduations representing less than .38 degrees and a total amplitude of .76 degrees to the left and .76 degrees to the right.
2) Vertical reaim.
On the assembly lines of the lamp manufacturer, each lamp is individually aimed thanks to photometric means. The car manufacturer, on its assembly lines, also aims each lamp with photometric means. The position of the seating plane of the housing is ch ecked carefully, and each bubble vial is set to zero and then blocked for life in this position by the lamp manufacturer. To reaim vertically:
2 1) Check the car fulfills the specifications of SAE J 599 May '81. 2 2) Measure the longitudinal angular value of the floor slope. Note the figure and its orientation, positive or negative. 2 3) Operate the aiming control until the bubble has slid by an equal number of fiducial marks in the appropriate direction. 2 4) Do the same for both lamps.
3) Horizontal reaim.
On the assembly lines of the car manufacturer, provisions are taken so that the zero position of the BH nut coincides with the specified aim. To reaim horizontally: Rotate the BH nuts until their fiducial mark coincides with the zero of their body counterparts.
4) Vertical reaim after accident dammage.
This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor of their premices must be rigid, flat and substantially horizontal.
4 1) Rotate the vertical aiming control until the bubble comes to the zero position. If, after severe dammage, the bubble can not reach the origin of the scale because the stroke of the aiming screw is too small, place shims between the body panel and t he housing.
5) Horizontal reaim after accident dammage.
The remarks of the preceeding paragraph also apply.
5 1) Set to zero the fiducial mark on BH, right hand side. 5 2) Remove the bulb service bonnets, and attach the string aimer to the reflector, as shown on section AA of attached documents. No mispositionning can happen, because the aimer for t he left hand lamp cannot fit into the right hand lamp.
5 3) Unroll the string from its right hand reel and affix it to the opposite string aimer. 5 4) Tightly prevent the BH nut from rotating, remove the cap 5 5) Operate the right hand screw AH until the string comes to the zero of
the fiducial marking on the right hand aimer. 5 6) Symetrizing the instructions, do the same for the left hand lamp, remove aimers, reinstall the bonnets.
It is important to note that this example does not exclude the use of conventionnal means, like the aiming screen or even the more modern fractionnal balance aiming machines. Like for vertical reaim after dammage, shims may be necessary if the stroke of the AH screw does not suffice.
Attachments
Drawing of string aimer left hand unit solution 2. (Graphics omitted.)
Drawing of horizontal aiming feature solution 2. (Graphics omitted.)