Mr. Rishi Gupta
Autolite (India) Limited
D-483 Road No. 9-A
Vishwalkarma Industrial Area
Jaipur 302 013
India

Dear Mr. Gupta:

This is in reply to your FAX of August 29, 1994, to Richard Van Iderstine of this agency. For future reference, requests for interpretations of U.S. Federal motor vehicle safety regulations should be addressed to the Office of Chief Counsel.

You have asked whether the size and types of aiming pads you propose to place on headlamps manufactured by Autolite conform to DOT specifications. You describe these headlamps as "a 7" round and a 200 x 142 mm rectangular replaceable halogen sealed beams [which] use a replaceable halogen bulb (HB2)." You enclosed diagrams showing "aiming pad's position as per SAE J1383 - 1992" (Figures 1 and 3), and in the manner you wish to place them on the Autolite lamps (Figures 2 and 4). We understand that these replaceable bulb headlamps are intended to be sold as replacements for sealed beam headlamps of the same dimensions.

Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, is the DOT specification that applies to Autolite's headlamps.

The aimability performance requirements for non-sealed beam headlamps are found in S7.8. of Standard No. 108. S7.8 allows any aiming pad pattern that will fit on the headlamp and that will allow any one of the available aiming adapters described in SAE J602 to be used on the headlamp.

Specifically, S7.8.1 in pertinent part allows non- sealed beam headlamps to be equipped with aiming pads to be used with the photometric procedures of SAE J1383 APR85 (not "1992" as you wrote) when being tested for photometric compliance, and to serve for the aiming reference when the lamp is installed on a motor vehicle. S7.8.5 allows an installed headlamp system to

be aimable with an externally applied aiming device. Under S7.8.5.1, this aiming device shall be the equipment specified in SAE Standard J602 OCT80 Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units.

You write that the aiming pad sizes and types you wish to use are identical to those on headlamps sold by Hella, and that ETL Testing Laboratories has told you that the aiming pad positions and types meet DOT specifications. This indicates that Autolite's headlamps would be mechanically aimable with SAE J602 equipment, and therefore permissible as meeting Standard No. 108. We recommend that Autolite verify mechanical aimability with SAE J602 equipment before certifying compliance with Standard No. 108.

Our engineering staff has reviewed your letter and asks that we point out the following errors in Autolite's Figures Nos. 2 and 4. Under both Figures, there is a reference to "HB-2 (H4 P43t)." The HB2 light source is not the same as the H4 P43t light source. The HB2 is a light source permitted by Standard No. 108 while the H4 P43t is not permitted by the Standard for motor vehicles. Under the drawing, the dimension "68.5" should be "68.58 +/- 0.51" (see Figure 4-4 of Standard No. 108). The dimensions of "32" and "52.0" must be the sum of two dimension "A"s from Figure 4-4, thus the sum is 42.16 +/- 0.25 + 42.16 +/- 0.25 = 84.32 +/- 0.50, not 84 as nominally calculated. Finally, with respect to Figure 4 only, because this lamp is intended to replace a 200 x 142 mm sealed beam lamp, the position of the aiming pads are not, but should be identical to the 200 x 142 mm sealed beam to facilitate mechanical aim when only one headlamp is replaced.

Sincerely,

Philip R. Recht Chief Counsel

ref:108 d:10/26/94