Mr. Mark A. Evans
Photometric Engineer
Calcoast - ITL
P.O. Box 8702
Emeryville, CA 94662

Dear Mr. Evans:

We have received your letter of February 9, 1996, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to motorcycle headlamps. Specifically you ask for confirmation that motorcycle headlamps using HB2 and/or HB4 light sources must comply with out-of-focus requirements.

As you note, Table III of Standard No. 108 incorporates by reference SAE Standard J584 Motorcycle and Motor Driven Cycle Headlamps, April 1964 as the basic Federal requirement for motorcycle headlamps. Neither SAE J584 nor any provision of Standard No. 108 limit the types of light sources that may be used in a motorcycle headlamp. This means that Standard No. 108 (SAE J584) may be met with a Type HB2 or Type HB4 replaceable light source.

Part of the requirements of Standard No. 108 (SAE J584) are the "Out-of-Focus Tests on Unsealed Units" specifications of Section K of SAE J575. Thus, we confirm your understanding that motorcycle headlamps using Type HB2 or Type HB4 light sources must comply with the out-of-focus requirements of SAE J575. However, the question arises as to which version of SAE J575 applies, the one in effect in 1964 when SAE J584 was adopted, or a later version.

Paragraph S6.1 of Standard No. 108 states that the SAE Standards included in Table III are those published in the 1970 SAE Handbook, except that, for headlamps, unless otherwise specified, the version of J575 is that of December 1988. Correctly, S6.1 should note that SAE J575 DEC88 is for

headlamps for motor vehicles other than motorcycles. SAE J575 DEC88 is paragraphed by numbers rather than by letters and, in any event, no longer includes an out- of-focus test for unsealed units. The version of SAE J575 that is subreferenced by J584 in Standard No. 108 is correctly SAE J575d, August 1967, the version published in the 1970 SAE Handbook. We appreciate the opportunity to provide this clarification.

If you have any questions you may refer them to Taylor Vinson of this Office (202-366-5263).


Samuel J. Dubbin Chief Counsel ref:108 d:3/4/96