ID: aiam4333

Dear Mr. Mehta: This is in reply to your letter of February 23, 1987, to the Departmen of Transportation. You mentioned an earlier letter dated January 9, 1987, enclosing a copy of your product catalogue, but I regret to say that this Office has not received it.; As a producer of motor vehicle lighting equipment, you have asked fo answers to the following questions:; >>>'1. Details of DOT/SAE approval required in marketing our Headlam Units 7 inch, 5 3/4 inch (Round) and Rectangular small and large'.<<<; In the United States no 'approval' is required to import the headlamp that you mention. However, the manufacturer must assure itself that the headlamp comply with the requirements of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* (essentially those of the SAE for round and rectangular sealed beam headlamps), and certify each one as meeting all applicable Federal motor vehicle safety standards. This certification is a DOT symbol on the headlamp lens.; >>>2. Can we market those lamps as referred in Para. No. 1 fitted wit 9004, 9005 and 9006 Bulbs. If There is any specifications/technical details available with you, please send us a copy.'<<<; The headlamps discussed in paragraph 1 are sizes traditionall associated with sealed beam headlamps, rather than with replaceable bulbs such as the DOT HB1 (9004), HB3 (9005), and HB4 (9006). However, it is permissible to produce headlamps in these sizes, which incorporate replaceable light sources that are specified by Standard No. 108. However, such headlamps must meet all the requirements of the standard applicable to replaceable bulb headlamps. I enclose(sic) a copy of Standard No. 108 for your information.; >>>'3. We understand that the use 9004, 9005, 9006 bulbs are permitte on Headlamps with Lens and Reflectors made of Plastic. Kindly advise, if we can use these Reflectors made of metal?'<<<; Yes, a headlamp may have a reflector of either plastic or metal. >>>'4. Details of approval required for High Beam Driving Lamps to b use for off- road vehicle.'<<<; >>>'5. The details of specfications (sic) for Driving Lamps to be use on Cars, Trucks, etc.'<<<; Standard No. 108 does not require vehicles to be equipped with drivin lamps and it establishes no requirement for them. If there are any specifications or approvals required, they are those of the individual States in which these lamps would be sold and used. For further information on State requirements you should write: American Association of Motor Vehicle Administrators (AAMVA), 1201 connecticut Avenue, N.W., Washington, D.C.; It is the position of this Department that any headlamp unit which i capable of replacing a passenger car headlamp must meet the applicable requirements of Standard No. 108, even if it may also be used on off-road vehicles.; You have also asked for copies of 'SAE F-80 Front Fog Lamps' an SAE-J-79 Motor Cycle Headlamps'. We are not familiar with these materials and advise you to write: Society of Automotive Engineers Inc., 400 commonwealth Drive, Warrendale, Pa. 15096. As for 'Specification for Driving Lamps Using H3 Bulb', this appears to be a European specification unknown to us, as the H3 bulb is one that is not widely used in the United States.; The following is a listing of those requirements that must be complete before shipments begin. You must:; 1. Appoint an agent for service of process in accordance with Title 49 Code of Federal Regulations, Part 551 (49 CFR 551).; 2. Provide information as specified in 49 CFR 566, 'Manufacture Identification.'; If you determine in good faith that any lamp manufactured by you doe not conform with Standard No. 108 or contains a safety-related defect, section 151 (15 USC 1411) of the Act requires that you furnish notification to the Secretary and to owners in accordance with section 153 (15 USC 1413) and to remedy without cost the failure to conform or defect in accordance with 154 (15 USC 1414). Details are contained in 49 CFR 573, 576 and 579.; We are enclosing the following pertinent publications: 1. The Act 2. 19 CFR 12.80, 'Regulations for Motor Vehicle Importation' 3. 49 CFR 551, 'Procedure Rules' 4. 49 CFR 573, 'Defect and Noncompliance Reports' 5. 49 CFR 576, 'Record Retention' 6. 49 CFR 579, 'Defects and Noncompliance Responsibility' 7. Information for New Manufacturers of Motor Vehicle and Motor Vehicl Equipment; If we may be of further assistance, please let us know. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam4394

Dear Mr. Pape: This is in reply to your letter of August 22, 1987, to Taylor Vinson o this office, enclosing a copy of your letter to George Walton of AAMVA. In that letter you have asked three questions with reference to the center highmounted stop lamp required by Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, to which you have asked that we reply.; Your first question is 'May one word be introduced on the brake light? Standard No. 108 prohibits combining the center highmounted stop lamp with any other lamp, or with any reflective device. It does not prohibit the addition of one or more words to the lens. However, there are basic requirements that the lamp must meet, and the word or words must not prevent the lamp from meeting them. Specifically, the effective projected luminous area of the lens must not be less than 4 1/2 square inches, and the lamp must meet specified candela maxima and minima at 13 discrete test points.; Your second area of interest is the color red. You have asked whethe it is a Federal requirement for all brake lamps, whether other colors may be substituted, and whether the color red may be adjusted to a lighter hue. Standard No. 108 requires all stop lamps to be red in color. This color is defined in SAE Standard J578c *Color Specification for Electric Signal Lighting Devices*, February 1977, expressing chromaticity coordinates according to the CIE (1931) standard colorimetric system. Red is rather narrowly defined, and falls with the y coordinates, 0.33 (yellow boundary) and 0.98 (purple boundary). Red is not acceptable if its is less saturated (paler), yellower, or bluer than the limit standards. Thus red could not be adjusted beyond the prescribed limits. In our opinion, the 'soft pink' or 'hot pink' that you believe is desirable would be beyond those limits. No color other than red is permitted for stop lamps.; Your final area of interest is whether one should consider marketing lamp with the features you have indicated, and whether there are 'hidden directives which would restrict or prohibit such marketing.' Under assumption that your lamp would not comply with the color requirements of Standard No. 108, we must advise you that a noncomplying lamp could not be sold as original equipment for passenger cars, or as a replacement for center high mounted stop lamps on passenger cars manufactured on or after September 1, 1985. Federal law would not prohibit its sale for use on vehicles other than these, but the lamp would be subject to the laws of any State in which it would be sold and used.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam4757

Dear Mr. Brown: This is in reply to your letter of April 25, l990 asking for our 'comments and approval' regarding an automotive lighting product that your company intends to market. The product is intended for use in a four headlamp systems with lens designations of 'L', 'LF' or 'HB4' on the outboard lamps, and 'U', 'UF' or 'HB3' on the inboard lamps. In normal operation, the lower beam is extinguished when the upper beam is activated, your device would ensure that the lower beam would remain activated when the upper beam is used. You view this as permissible under S5.5.8 of Motor Vehicle Safety Standard No. 108. Initially, let me note that we have no authority to 'approve' any device or invention for use on motor vehicles. We advise whether such products are permissible under the Federal motor vehicle safety standards, but this advice must not be represented in advertising as Federal approval of the device or invention. Section S5.5.8 of Standard No. 108 states in pertinent part that 'On a motor vehicle equipped with a headlighting system designed to conform to the photometric requirements of Figure 15, the lamps marked 'L' or 'LF' may be wired to remain permanently activated when the lamps marked 'U' or 'UF' are activated. Standard No. 108 further specifies that headlamps designed to conform to Figure l5 are the four-lamp sealed beam system Type F (S7.3.7(b)), and a four-headlamp integral beam system (S7.4(a)(1)). In addition, certain types of replaceable bulb headlamp systems may also be designed to conform to Figure l5 photometrics, as shown in recently-adopted Figure 26 (copy enclosed). Replaceable bulb headlamps are also required to have the HB Type number on the lens, as well as the 'U' and 'L' markings. Therefore, installation of your device on the headlighting systems mentioned above would be permitted by Standard No. 108, and you need not be limited to systems that use HB3 and HB4 light sources. With respect to the copy on the material you submitted for review, it would be more accurate to reword the marking references to state ''LF','L', or 'L' and 'HB4' on the upper. . . and the corresponding designation 'UF', 'U', or 'U' and 'HB3' on the lower. . . .' We also note your remark 'Quad-Beam gives you this extra margin of lighting safety that the factory left out.' There is no basis in fact for this statement. Some drivers prefer more foreground light, but there is no indication that the addition of the lower beam when the upper beam is in use has a positive effect upon lighting safety. As you requested, we are returning your samples. Sincerely, Paul Jackson Rice Chief Counsel Enclosures;

ID: aiam4657

Dear Mr. Faber: This is in reply to your letter of August 9, l989, wit respect to the interpretation of the word 'headlamp' as it appears in paragraph S7.2 of Motor Vehicle Safety Standard No. 108. In pertinent part, this paragraph specifies that certain markings shall be placed on the lens of each headlamp, with 'each headlamp' to be marked with the voltage and part or trade number. Noting that 'headlamp' is not a defined term but 'replaceable bulb headlamp' is, you have asked for confirmation that marking the lens, the reflector, or the light source with the voltage would be in compliance with paragraph S7.2. The agency intends that the voltage be indicated on the exterior of the headlamp. If the manufacturer does not wish to put it on the lens, Standard No. 108 will permit, as of December 1, l989, voltage marking to be on an exterior part of the headlamp body, but not on the light source. I hope that this answers your question. Sincerely Stephen P. Wood Acting Chief Counsel /;

ID: nht87-2.57

TYPE: INTERPRETATION-NHTSA

DATE: 07/23/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase -- Manager, Technical Administration Dept., Koito Mfg. Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Manager, Technical Administration Dept. Koito Mfg. Co.. Ltd. Shizuoka Works 500, Kitawaki Shimizu-Shi, Shizuoka-ken Japan

Dear Mr. Iwase:

This is in reply to your letter of March 24, 1987, asking two questions with respect to Motor Vehicle Safety Standard No. 108.

Your first question concerns an aiming adaptor for replaceable bulb headlamps whole lenses may slant 60 degrees from the vertical or horizontal. You have discovered that the Hopkins universal adaptor cannot be used with these headlamps, and you propose t o provide a special adaptor with each vehicle equipped with such headlamps, as well as aiming adjustment procedure information in the vehicle's service manual. You ask for confirmation of your belief that this is permissible under Standard No. 108.

Standard No. 108 does not require that an aiming adaptor be provided with a motor vehicle, only that its headlamps be capable of mechanical aim. Therefore there is no legal requirement that the adaptor be provided. However, without such an adaptor, an ow ner of a vehicle with the 60-degree headlamps may encounter difficulties at State inspection stations where mechanical aimers are in use, and at repair facilities when headlamps are replaced or after body work has been performed that necessitates reaim o f headlamps. Therefore we believe that provision of the adaptor and aiming information would enhance consumer acceptance of the 60-degree headlamps.

Your second question concerns the legality of the upper aiming boss on a low profile headlamp. Because the height of the lens is insufficient to incorporate the upper aiming boss, you propose to place it on a flange of the lens in a "photometrically inef fective area." However, the flange is concealed when the hood is shut, and the hood must be opened in order for aiming adjustment to occur. You believe that this is acceptable under Standard No. 108 and ask for our confirmation.

Paragraph S4.1.1.36(a)(2) requires that "the lens or each replaceable bulb headlamp shall have three pads which meet the requirements of figure 4...." Your drawing indicates that the flange is part of the headlamp lens even though that portion of the len s is not needed to provide illumination. Therefore this design would appear to meet the requirements of Figure 4 as you have concluded.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Admin. 400 Seventh Ave., S. W. Washington D.C., 20590 USA

Dear Ms. E. Z. Jones

We would like to ask you the following question concerning aiming adjustment for bulb replacement headlamp.

RE: 1) Aiming Adaptor for 60o Slant Bulb Replaceable Headlamp

We are developing and engineering-designing of bulb replaceable headlamp whose lens slants up to about 60o in vertical and horizontal as shown below.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

Upon our technical review, we have come to conclusion that this headlamp would be able to meet with all of the requirements specified in FMVSS NO. 108.

This headlamp lens has three pads which meet the requirements of Figure 4, Group II Aiming Pad Location (prescribed for 1A1, 2A1 sealed beam unit) and is marked "22H62V" for aiming in accordance with S4.1.1.36-(a)(3) of FMVSS NO. 108.

This headlamp is designed, in accordance with S4.1.1.36(b)(3), so that it would be aimed by use of mechanical aimer specified in SAE J602C.

However, when this headlamp is installed onto the vehicle, the following inconvenience will come about to the aiming of this headlamp, we are afraid.

When user, dealer or vehicle inspection station try to perform aiming of this headlamp by use of the aimer specified in SAE J602C, the universal adaptor (Hopkin's smaller adaptor; stock #0203 - refer to the attached pamphlet) cannot be used onto this hea dlamp.

Because Hopkin's adaptor has the adjustable range in angle of suction cup which is limited within 35o max and adjustable length of legs within 4.0 in. max.

However, this headlamp requires 60o in its adjustable range and 6.2 in. in its adjustable length of legs.

For the above possible inconvenience, we have no other choice but to have each vehicle provided with a set of special adaptor for this headlamp (shown below) so that it could be made mechanical aiming adjustment by means of the aimer specified in SAE J60 2C, we think.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

The information of aiming adjustment procedures for this headlamp shall be put into vehicle service manual, we think.

Question-1):

We believe that this special adaptor and our countermeasure fully meet with FMVSS NO. 108 and have nothing illegal under FMVSS NO. 108.

We would like you to confirm that our interpretation is correct.

RE: 2) ARRANGEMENT OF AIMING BOSS FOR LOW PROFILE HEADLAMP

We are developing and engineering-designing such a low profile headlamp as the height of its lens is not enough to apply to the aiming boss arrangement in Fig. 4 of FMVSS NO. 108.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

Accordingly we have an idea to have aiming boss arranged as shown below.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

(1) The upper aiming boss is located on the flange of lens which is photometrically ineffective area.

(2) The aiming boss location is applied to Fig. 4 of FMVSS NO. 108.

(3) However, the upper boss is located in a part which is covered by the bonner and so the bonner must be opened when aiming adjustment is made.

Question-2):

We believe that the aiming boss arrangement as abovementioned can be applied to FMVSS NO. 108 and have nothing illegal under FMVSS NO. 108.

We would like you to review and confirm that it is correct.

Upon your review, your prompt reply to this matter would be greatly appreciated.

Sincerely

M. Iwase, Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works

Attached: Copy of Universal Adaptors Pamphlet

SEE HARD COPY FOR GRAPHIC AND ADDITIONAL TEXT INFORMATION

ID: nht87-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 12/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase, Manager, Technical Administration Dept. Koito Mfg. Co., Ltd.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 7/23/87 letter from Erika Z. Jones to M. Iwase (Std. 108)

TEXT:

Mr. M. Iwase, Manager Technical Administration Dept. Koito Mfg. co., Ltd. Shizuoka Works 500, Kitawaki Shimuzu-shi, Shizuoka-ken JAPAN

This is in reply to your letter of September 15, 1987, with further 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 t he 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) specifically 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 a iming pads would be one that is not designed to conform to the standard.

The agency is examining concepts for aiming methods for other than 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

Air-Mail Ms. Erica Z. Jones Chief Counsel National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. E. Z. Jones:

We would like to further ask you the following question of headlamp aiming adaptor in connection with your kind advice mentioned in your letter of July 23, l987 replying to our letter of March 24, l987. (Refer to the attached.)

RE = 1 ) Aiming Adaptor for 60 " Slant Bulb Replaceable Headlamp

As shown below, instead of being installed, on the lens of headlamps, aiming bosses are installed on the surface of the special adaptor which is to be equipped onto each vehicle so that mechanical aiming can be performed, by use of the headlamp aimer " s pecified SAE J602C.

Of course, the special adaptor is so designed that it can be surely attached onto the proper design position of headlamps.

The aiming bosses and markings, which are applied to 54. 1. 1.36 (a) (2)& (3) of FMVSS No. 108, are placed on the surface of the special adaptor.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 2 / 3

Question:

We believe that the aiming boss installation as abovementioned can be applied to FMVSS NO. 108 and not illegal under FMVSS NO. 108. We would like you to confirm whether our interpretation is correct or not.

Aiming pads are specified in 54.1. 1.36 (a) (2) of FMVSS NO. 108 as follows;

"The exterior face of each replaceable bulb headlamp lens shall have three pads which meet the requirements of Figure 4, Dimensional Specifications for Location of Aiming Pads on Replaceable Bulb Headlamp Units .. ."

However, for all this prescription, we can not find it necessary that aiming pads shall be placed on the lens of headlamps which can be aimed by the use of the adaptor equipped onto each vehicle, because the special adaptor can be designed regardless of lens bosses so as to be surely attached onto the proper design position of headlamps in any way, we think.

And it is not only useless but also impractical that the specified aiming bosses are placed onto the lens of headlamps which slant up to about 60o in vertical and horizontal, because the projection of the aiming bosses becomes higher according to the len s slant inevitably.

(INSERT GRAPHICS)

Attn: Ms. Erica Z. Jones Date: Sept. 15, 1987 Page: 3 / 3

Upon our consideration of the abovementioned matter, it should not be required that aiming bosses shall be placed on the lens of headlamps which are aimed by use of the special adaptor equipped onto each vehicle.

Upon your review, your prompt reply to this matter would be greatly appreciated.

Very truly yours, M. Iwase Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works

See 7/23/87 letter from Erika Z. Jones to M. Iwase.

ID: aiam4895

Dear Mr. Hanna: This responds to your letter of July 8, 1991, t Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations. You intend to petition for rulemaking to amend Standard No. 108 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on 'antique cars.' Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are 'for display purposes only and not approved for highway use.' Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for 'display purposes only.' The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. 108, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act. The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification that is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act. Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires. Sincerely, Paul Jackson Rice Chief Counsel;

ID: aiam4896

Dear Mr. Hanna: This responds to your letter of July 8, 1991, t Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations. You intend to petition for rulemaking to amend Standard No. 108 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on 'antique cars.' Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are 'for display purposes only and not approved for highway use.' Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for 'display purposes only.' The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. 108, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act. The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification that is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act. Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires. Sincerely, Paul Jackson Rice Chief Counsel;

ID: nht79-2.45

DATE: 05/09/79

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Koito Manufacturing Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 29, 1979, to Bill Eason with respect to headlamp lens marking. Mr. Eason is no longer associated with the Office of Rulemaking and we regret the delay in writing you.

You have asked for a confirmation of your interpretation that:

"The headlamp designed to conform to J579c shall be provided with the lens marking specified in S4.1.1.21 of FMVSS No. 108 even if the upper beam headlamp maximum output is lower than the conventional maximum restriction of 37,500 cd."

You are correct that S4.1.1.21 permits the new code marking for headlamps designed to conform to SAE Standard J579c even if the upper beam headlamp maximum output is lower than the maximum of 75,000 cd permissible under 579c or the previous maximum of 37,500 cd of J579a. But because the code could be misleading, we are considering proposing an amendment of Standard No. 108 that would delete the new code requirement for all headlamps whose maximum candela does not exceed a certain value, such as 40,000 cd.

SINCERELY,

Bill Eason Office of Rulemaking National Highway Traffic Safety Administration

January 29, 1979

Subject: Headlamp Lens Marking

Reference: Docket No. 78-5; Notice 3 of Federal Register Vol. 43, No. 145 dated July 27, 1978

Dear Sir:

With reference to the headlamp lens marking, the latest S 4.1.1.21 of FMVSS No. 108 as amended in Docket No. 78-5; Notice 3 of FR Vol. 43, No. 145 dated July 27, 1978, provides as follows;

Quoted " S 4.1.1.21 The lens of each headlamp designed to confom to SAE Standard J579c, Sealed Beam Headlamp Units for Motor Vehicles, December 1974, manufactured on or after July 1, 1979, shall be marked with the symbol ------------ -------- ." unquoted

The NHTSA's basic intention of establishing the above lens marking code is to give consummers a means of identification to determine which the photometric and beam pattern design specified in either SAE J579c or SAE J579a does apply to the headlamp and also to enable them to replace original headlamp with headlamp of compatible photometric properties, we believe.

In addition, it can be said that the headlamp designed to conform to SAE J579c is substantially different also in the upper and lower beam patter distribution as well as being different in the upper beam photometric maximum output, when compared with the headlamp of SAE J579a, we think.

KOITO MANUFACTURING CO., LTD.

Attn. Bill Eason Office of Rulemaking National Highway Traffic Safety Administration Dated January 29, 1979

We would hereby ask you to provide us with your definite confirmation and our interpretation is as follows;

The headlamp designed to conform to SAE J579c shall be provided with the lens marking specified in S 4.1.1.21 of FMVSS No. 108 even if the upper beam headlamp maximum output is lower than the conventional maximum restriction of 37,500 cd.

If you have another interpretation of this code to this matter, please kindly let us know soonest possible because we have to change lens moulds to provide our headlamp with the proper marking.

Upon your kind review to this matter, your prompt reply would be greatly appreciated.

M. Iwase Chief, Overseas Technical Section Technical Administration Department Koito Manufacturing Co., Ltd. Shizuoka Works

PS: POSTAGE STAMP ENCLOSED FOR YOUR REPLY BY AIR.

ID: nht76-2.40

DATE: 10/22/76

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: ACUTEK

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 13, 1976, to Mr. Lewis C. Owen, Safety Standards Engineer, concerning an interpretation of the words "optically combined" as they apply to your Acutek 301 combination rear lamp.

In the Acutek lamp, the data you submitted indicate that when the taillamp bulb is activated independently from the clearance lamp bulb, and vice versa, there is no appreciable amount of incidental light emitted from the lens of the clearance lamp. The amount of light "spill" appears to be so small that it would not be interpreted (by a driver following the vehicle on which it is installed) as illuminating the lens of the taillamp when operated in the clearance lamp mode, and vice versa.

Accordingly, the Acutek 301 combination rear lamp appears to meet the requirements of Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment."

SINCERELY,

Acutek

October 13, 1976

Louis C. Owen

NHTSA

Subject: Acutek 301 light

Since our telephone conversation in which you stated that in the opinion of your office you feel the Acutek 301 tailight and clearance light is optically combined therefore it is not in strict compliance with standards.

I have had time now to consider Acutek's position and feel the design of the lamp does not conflict with S4.4.1 of MVSS 108 which states: "two or more lamp, reflective devices or items of associated equipment may be combined if the requirements for each lamp, reflective device and item of associated equipment are met except that no clearance lamp may be COMBINED OPTICALLY with any tail light or identification lamp.

I think the key words are "COMBINED OPTICALLY". It would seem to me that in order for a lamp to be combined optically you would either have to use the tail light lens or the 2 candlepower filament of the bulb for tail light or both to have a lamp that is optically combined tail and clearance. In reviewing the engineering and the Acutek light I find that we are not using either the tail light filament for the tail light lens to accomplish the clearance function. In fact the clearance function is combined with the side marker lens and uses the side marker bulb to accomplish the clearance function. The lamp will not pass for clearance side marker using only the tail light filament also it will not pass for a tail light using only the side marker bulb. In my opinion the Acutek 301 light does not conflict with S 4.4.1 as the clearance light is not optically combined with the tail light and in fact is completely separated from the tail light by a section of reflex reflector.

It is true there is some very small amount of bleed over light from one section of the lamp to the other. This feature does not in any way decrease the effectiveness of the lamp, but rather is an added safety feature.

For some reason there has been an unusually large amount of controversy concerning this lamp design and feel it is unwarranted. Frankly the controversy has been a deterrent to the sales program and I would like to resolve the question of whether or not the light does in fact comply with MVSS108.

I would like for your office to reexamine the Acutek 301 tail light, keeping in mind that to be optically combined the lamp would use the tail lamp section to accomplish the clearance requirement. Since the lamp does not do this there is not doubt in my mind upon re-evaluation you will agree the lamp does meet requirements and will be in aposition to send me a letter so stating.

At the Chicago Boat Show I had the opportunity to look at the new Truck Lite combination lamp, in my opinion this light does not meet MVSS 108 as they are using the tail light lens to accomplish the clearance function.

Enclosed with this letter is the ETL test reprt which indicates the Acutek 301 rear lamp does comply with all requirements for tail, stop, turn, rear reflex, side marker and reflex, clearance and license illuminator including photometric, lens warpage, color, corrosion, vibration, moisture, dust and bulb socket.

In order to reactivate the sales program, I need a letter form you indicating compliance or what needs to be done to the lamp to bring it into compliance. It is important that this be done as soon as possible for the manufacturers of boat trailers are now placing orders for next years requirements and if there is much more delay on my part then my competitors will have succeded in keeping me out of the market. I do not intend to let this happen.

Upon your re-evaluation of the Acutek 301 lamp I am sure you will agree the clearance lamp is not optically combined with the tail lamp but is combined withthe side marker lens and bulb.

I thank you for your consideration.

Kenneth C. Ploeger President

Report Electrical Testing Laboratories, Inc.

Order No. 97552-L

Date August 30, 1976

REPORT NO. 436523 "*ACUTEK 301 DOT SAE A.I.S.T 76" COMBINATION REAR LAMP (WITH OR WITHOUT LICENSE PLATE ILLUMINATOR) AND COMBINED WITH "ACUTEK 201 DOT SAE APC - 76" LENS - CLEARANCE, SIDE MARKER LAMP AND REFLEX REFLECTOR

RENDERED TO

ACUTEK INC.

INTRODUCTION

This report contains the results of examination and test of the above device to demonstrate compliance with the applicable test requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, effective January 1, 1976 and current indicated SAE Standards as requested by the client. Marks of identification comply with the requirements of CAC, Title 13, California Highway Patrol.

[Report Omitted]