Interpretation ID: nht76-2.27

DATE: 03/12/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: CaL Light Co.

TITLE: FMVSS INTERPRETATION

TEXT: In your latestletter, dated February 17, 1976, you asked "Does the Federal motor vehicle safety standards allow the use of one half of an automobile headlight system on a motorcycle?"

There is no Federal prohibition against an owner modifying his motorcycle to use any lighting configuration, though there may be State or municipal restrictions. The answer where a manufacturer is involved, however, depends upon the type of automobile headlamp system used. Motor Vehicle Safety Standard No. 108 requires a motorcycle to be equipped with a headlamp system conforming to SAE Standard J584, Motorcycle and Motor Driven Cycle Headlamps, April 1964. Two options allowed are use of a single 7 inch sealed beam unit, or of one 5 3/4 inch Type 1 and one 5 3/4 inch Type 2 sealed beam unit, provided these headlamps meet the requirements of SAE J579a, Sealed Beam Headlamp Units for Motor Vehicles, August 1965. Thus, "one half" of a two-headlamp, or of a four-lamp circular lens passenger car headlighting system could be used on a motorcycle. But use of a system comprised of one Type 1A plus Type 2A (rectangular lens), is not currently permitted under Standard No. 108.

Since there is an equivalence of performance between rectangular and circular lens headlamps systems, if you wish to merchandise a two-lamp (Type 1A plus Type 2A) rectangular system for use on motorcycles, you may wish to submit an additional petition for an amendment of Standard No. 108.

Yours truly,

ATTACH.

CAL LIGHT CO.

February 17, 1976

RICHARD B. DYSON -- U.S. DEPARTMENT OF TRANSPORTATION, NHTSA

Dear Mr. Dyson,

In reply to your letter of February 12, 1976, first of all, we did not at that time, December 10, 1975, petition the NHTSA for an ammendment. The petition for ammendment was filed on January 27, 1976 by our letter of January 14, 1976.

I have recieved much stationary from your office, however, little of it pertains to the basic context of my letters. I shall request basically the same as I have in my previous letters, although I shall use a different format. I would like your office to give me a yes or no answer on the following question, Does the Federal motor vehicle saftey standards allow the use of one half of an automobile headlight system on a motorcycle?.

I shall be awaiting your prompt reply.

Truly,

Lawrence MacEachern