Interpretation ID: nht90-2.32

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1990

FROM: Peter K. Brown -- President, KC HiLites, Inc.

TO: Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-2-90 to Peter Brown from Paul J. Rice; (A35; Std. 108) TEXT:

I am writing for your comments and approval regarding an Automotive Lighting product that our company intends to market.

The headlight systems on many late model vehicles operate differently than in the past. The low beams are extinguished when the high beam units are in use. This was done to reduce the foreground light of the low beams when the high beams are in use. I n actual use, having both systems operating in the high beam mode is superior.

With this in mind, I have studied paragraph 5.5.8 of the Federal Register Volume 54, No. 88 dated May 9, 1989. I interpret this to mean that headlights of a specific type, when used in a 4 headlight system, can all be illuminated at the same time on Hig h Beam.

The intended packaging, product and retail header card are enclosed for your inspection. I welcome any suggestions or comments that you may have. As these are prototype packages, will you please return them with your comments.

Our product catalog is enclosed to give you some idea of our company and products. Thanks for your help.