Kiyoshi Narabu, General Manager
Ichikoh Industries, Ltd.
Technical Department
80 Itado, Isehara
Kanagawa, 259-11
Japan

Dear Mr. Narabu:

This is in reply to your letter of April 21, 1997, asking for an interpretation of Motor Vehicle Safety Standard No. 108, specifically, the final rule allowing visually/optically aimable headlamps.

Your first question is:

"S7.8.2.1(c) prescribes that a visually/optically aimable lower beam headlamp shall not have horizontal adjustment mechanism other than VHAD. We consider that some kind of horizontal adjustment mechanism are necessary to align lamp axis with vehicle axis at lamp installation on the vehicle. Does horizontal adjustment mechanism that uses only at installation and can not be adjusted by vehicle owner or driver conform to requirement of S7.8.2.1(c)?"

We understand that it is necessary to align properly the horizontal aim at the time the headlamp is installed on a motor vehicle. We do not understand why a horizontal adjustment mechanism has to be a permanent part of the headlamp or vehicle. However, if its design is such that it can never be used again, even with special tools, we would not consider that the installation of a horizontal adjustment mechanism of this type creates a noncompliance with paragraph S7.8.2.1(c).

"S7.8.5.2(c) require permanent fixation of VHAD device calibration on or after September 1, 1998. Does calibration method that vehicle owner or driver can not calibrate using ordinary tools conform to this requirement?"

Your question implies that the calibration can be adjusted by tools that are not "ordinary tools." If the calibration is capable of adjustment by any means, it is not "permanent" within the meaning of the requirement. If the calibration cannot be adjusted, by ordinary tools or otherwise, then it is permanent within the meaning of paragraph S7.8.5.2(c).

If you have any questions regarding this letter, you may contact Taylor Vinson of this Office (FAX 202-366-3820).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:6/11/97