Interpretation ID: nht91-4.42

DATE: July 8, 1991

FROM: Ken Hanna -- Lectric Limited Inc.

TO: Richard Van Iderstine -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-29-91 from Paul Jackson Rice to Ken Hanna (A38; Std. 108)

TEXT:

In reference to our last conversation regarding the manufacturing of sealed beam bulbs for antique cars. As per your suggestion, we are gathering data so that we may submit a comprehensive petition with all pertinent information included requesting reinstatement of SAE J579A.

Since it may take up to two years to reinstate SAE J579A and we are anxious to get our sealed beam headlight project underway, we would like to manufacture bulbs in the interim which meet J579C specifications in terms of candlepower and photometrics. However, since these bulbs will lack various identification nomenclature on the face of the lenses which are required by SAE J579C we would like to market these bulbs with clear identification on the packaging identifying them "for display purposes only and not approved for highway use". I discussed this possibility with you in our last conversation and as I recall you felt that NHTSA had no jurisdiction over products which are not intended for highway use and do not fall under the same regulations and specifications required of products which are intended for highway use.

Please let me know as soon as possible whether or not we will be violating any NHTSA restrictions by manufacturing and marketing these bulbs in this manner.