Mr. L. W. Camp
Director, Automotive Safety Office
Environmental and Safety Engineering
Ford Motor Company
330 Town Center Drive
Dearborn, MI 48126

Dear Mr. Camp:

This replies to your letter of December 16, 1997, to Dr. Martinez asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S7.8.2 of Standard No. 108 requires that the mounting and aiming mechanisms of headlamps installed on motor vehicles be accessible without the removal of any vehicle parts "except for protective covers removable without the use of tools." You ask whether "a hard object, such as the vehicle ignition key" is a "tool" within the meaning of S7.8.2.

We have concluded that an ignition key is a "tool" as contemplated by S7.8.2. A "tool" is defined as "1. An implement, esp. one held in the hand, as a hammer, saw, or file for performing or facilitating mechanical operation. 2. Any instrument of manual operation." (Random House Complete Unabridged Dictionary, Special Second Edition, 1996, at p. 1995).

The ignition key, or any other hard object, is an instrument of manual operation held in the hand to facilitate the removal of the headlamp covers, and therefore a "tool." Compare with S5.1.1.27(a)(5) and (b)(4) which specify that center high mounted stop lamps "shall provide access for convenient replacement of the bulbs without special tools" (emphasis supplied). Had you asked whether an ignition key was a "special tool" we might well have said that it is not, because any hard object could be used to provide access to the bulbs and access does not require a tool specifically designed for that purpose.

We note that Ford initially intended that all covers be removable by hand, and that the reason for your request is that "manufacturing variation of the plastic push pins and vehicle structure can result in elevated retention forces" in "approximately 30% of the attachments." While this is regrettable, identification of the problem at this stage should allow Ford time to resolve this problem before production of your 1999 vehicle commences and forestall any question of compliance with S7.8.2.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.2/12/98