Interpretation ID: 12200.ztv

Mr. Don Weidman
Mgr., Special Project
Grote Industries, Inc.
P.O. Box 1150
Madison, IN 47250-0550

Dear Mr. Weidman:

This responds to your letter of July 9, 1996, asking for an interpretation of paragraph S7.8.5 of Federal Motor Vehicle Safety Standard No. 108.

The sentence that concerns you reads as follows: "When activated in a steady-burning state, headlamps shall not have any styling ornament or other feature, such as a translucent cover or grill, in front of the lens." You ask whether a transparent cover is permissible.

No cover of any sort is permissible. The standard is absolute in its prohibition and merely uses translucent covers and grills as examples of items that may not be placed in front of a lens. The reason for the prohibition is to preserve original photometric performance of the headlamps, and to prevent deterioration from interference by grills, or which might occur over time from moisture, scratching, and other environmental factors that can affect headlamp covers, whether translucent or transparent.

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

Sincerely,

Samuel J. Dubbin

Chief Counsel

ref:108
d:8/12/96