Interpretation ID: 1983-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 06/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc. -- H. Nakaya, Manager

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield, MI 48075

Dear Mr. Nakaya:

This is in reply to your letter of May 24, 1983, asking whether the headlamp bezel is considered a "styling ornament or other feature" for purposes of paragraph 5.2 of SAE J580 Sealed Beam Headlamp Assembly, Aug 79 incorporated by reference in Standard No. 108.

The referenced SAE paragraph prohibits styling ornaments or other features in front of the lens when the headlamp is in use. The intent of this paragraph is to guarantee optimum light output from the headlamp by insuring that no part of the vehicle interferes with the light pattern. If a headlamp bezel is so large that it could interfere with the design light patterns of the lamp, we would consider it a "styling ornament or other feature" within the meaning of paragraph 5.2.

An oversize bezel interfering with light output would also be prohibited by paragraph S4.1.3. of Standard No. 108 which prohibits installation of motor vehicle equipment that impairs the effectiveness of lighting equipment which the standard requires.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel May 24, 1983

Our Ref. No.: SDL3-016

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

Per a recent phone conversation from a member of my staff to Mr. Taylor Vinson, we request a clarification concerning FMVSS108: Lamps, Reflective Devices, and Associated Equipment.

Our question is: Is the headlamp bezel included in "... any styling ornament or other feature..." which is explained in SAE J530 5.2.

Of course, the performance of the headlamp satisfies all requirements of FMVSS108.

We are looking forward to receiving your response as soon as possible.

Very truly yours,

H. Nakaya Manager

HN/ab

cc: Mr. Taylor Vinson