Interpretation ID: aiam4414
Manager
Technical Administration Dept.
Koito Mfg.
Co.
Ltd.
Shizuoka Works
500
Kitawaki
Shimuzu-shi
Shizuoka-ken
JAPAN;
Dear Mr. Iwase: This is in reply to your letter of September 15, 1987, with furthe reference to features of a 60 degree slant replaceable bulb headlamp presently being developed by Koito. You have explained that the aiming pads for the new system will be installed on the aiming adapter, rather than the headlamp lens, and have asked for confirmation that this is 'not illegal' under Motor Vehicle Safety Standard No. 108.; As you noted in your letter, paragraph S4.1.1.36(a)(2) specificall requires the exterior face of each replaceable bulb headlamp lens to have three aiming pads. The agency has no specifications for the design of aiming adapters, and a headlamp without aiming pads would be one that is not designed to conform to the standard.; The agency is examining concepts for aiming methods for other tha mechanical aim, but no amendments to Standard No. 108 are contemplated that would permit or require aiming pads to be on aiming adapters.; Sincerely, Erika Z. Jones, Chief Counsel