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

Dear Mr. Narabu:

This is in reply to your letter of July 16, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108, specifically, the final rule allowing visually/optically aimable headlamps, published on March 10, 1997 (62 FR 10710).

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. Does the lower beam headlamp described below conform to requirement of S7.8.2.1(c)?

A) Having horizontal aiming device and capable of adjustment on lamp alone but when installed on the vehicle it will be disabled the adjustment because vehicle structure or components prevent access to the adjusting screws.

B) After adjustment, cover the screw head with cap or others prevent the access to the adjusting screw. Unless vehicle user or driver destroy the cap structure, the lamps shall not have capability of adjustment."

Paragraph S7.8.2.1(c) states that a visually/optically aimable headlamp that has a lower beam shall not have a horizontal adjustment mechanism, unless the mechanism meets the requirements of S7.8.5.2. New paragraph S7.8.5.2(c) was added as part of the visually/optically aimable headlamp specifications on March 10, 1997. This new paragraph applies to headlamps equipped with VHADs manufactured for use on motor vehicles manufactured on and after September 1, 1998, and requires that the calibration be fixed. The headlamp you describe appears to incorporate a VHAD that will be used only on the headlamp, at the time the headlamp was manufactured, and is not intended to be used thereafter. We view this design as conforming to the requirement of S7.8.5.2(c) that calibration be permanently fixed.

Your second question is whether NHTSA's failure to amend S7.8.5.2(a)(2)(iv) is an oversight, since the preamble indicated that the paragraph would be changed to eliminate an inconsistency. Yes, this was an oversight which we shall correct shortly.

Finally, you have said that "S7.8.5.2(c) does not specify the application of calibration for horizontal VHAD device or vertical VHAD device," and asked whether the requirement applies only for the horizontal VHAD device. Effective with vehicles manufactured on or after September 1, 1998, S7.8.5.2(c) requires that each headlamp equipped with a VHAD have its calibration permanently fixed. The definition of VHAD in S4 of Standard No. 108, as amended on March 10, 1997 (62 FR at 10717) indicates that it is a device used for determining the horizontal aim of a headlamp, or vertical aim, or both horizontal and vertical aim. Thus, the prohibition will apply to any VHAD with which a headlamp will be equipped, horizontal, vertical, or both.

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.10/30/97