Interpretation ID: 20161.ztv
Mr. Ron Woodward, P.E.
Section Supervisor Optics & Adv. Eng.
Federal-Mogul Corporation
Lighting Products
2513 58th Street
Hampton, VA 23661
Dear Mr. Woodward:
This is in reply to your letter of June 7, 1999, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.
S7.8.2.1(c) of Standard No. 108 states that:
A visually/optically aimable headlamp that has a lower beam shall not have a horizontal adjustment mechanism unless such mechanism meets the requirement of paragraph S7.8.5.2 of this standard.
Paragraph S7.8.5.2 requires each headlamp system that is capable of being aimed by equipment installed on the vehicle to include a Vehicle Headlamp Aiming Device (VHAD) that conforms to the remainder of the paragraph. Paragraph S7.8.5.2(a)(2)(iv)requires that the horizontal indicator of a horizontal adjustment mechanism of a VHAD
shall be capable of recalibration over a movement of +/- 2.5 degrees relative to the longitudinal axis of the vehicle to accommodate any adjustment necessary for recalibrating the indicator after vehicle repair from accident damage.
You ask for
a ruling on the acceptability of a horizontal adjustment system which purposely does not meet the +/- 2.5 degrees horizontal adjustment requirement and does not incorporate the VHAD indicator, on the assertion that since they purposely do not meet the requirements for the permitted horizontal adjuster system that the system qualifies as not having a horizontal adjuster system.
You give as an example a lamp that has a +/- 1 degree of horizontal travel.
You are asking for an interpretation that a system that adjusts a headlamp horizontally but which differs from the specifications of S7.8.5.2 is not a "horizontal adjustment system" within the meaning of S7.8.2.1(c). We cannot provide the interpretation you seek. You admit that the headlamp is not fixed but is adjustable horizontally up to +/- 1 degree. As you note, "[t]he standard
. . . states that the only acceptable type of horizontal adjuster is a horizontal adjuster which conforms to the horizontal VHAD requirements contained in the standard."
Standard No. 108 is quite clear on this point: a manufacturer need not provide a horizontal adjustment mechanism on a headlamp that is visually/optically aimable and has a lower beam. But if the manufacturer chooses to provide a mechanism that adjusts the headlamp, it must meet all requirements of S7.8.5.2 including the +/-2.5 degree specification, even if the headlamp itself is designed for only +/- 1 degree of horizontal travel.
Because we cannot concur with your desired interpretation, we are treating this matter as a petition for rulemaking in accordance with your request. We have forwarded your letter to the Associate Administrator for Safety Performance Standards who will respond to your petition.
If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.8/20/99