ID: 2876yy

Mr. Delbert N. Pier
Legislation and Compliance Coordinator
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108

Dear Mr. Pier:

This is in reply to your letter of February 11, l99l, asking for an interpretation of Motor Vehicle Safety Standard No. l08.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector) of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. l08.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:3/l4/9l

ID: nht91-2.31

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 2-11-91 from Delbert N. Pier to Paul Jackson Rice (OCC 5720)

TEXT:

This is in reply to your letter of February 11, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108.

ID: 19884.ztv

Mr. Ron Woodward, P.E.
Section Supervisor Optics & Adv. Eng.
Federal Mogul
2513 58^th Street
Hampton, VA 23661

Dear Mr. Woodward:

This is in reply to your letter of April 19, 1999, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment as it applies to a proposed horizontal alignment system for use with visual/optical aim headlamps.

Paragraph 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 requirements of paragraph S7.8.5.2 of this standard." You reference previous interpretations of this office which state "that disabled horizontal adjusters are acceptable [i.e., are not horizontal aim mechanisms within the meaning of the phrase]," that "certain types of anti-tamper screws are not permitted" ("ones that can be driven in one direction"), but not all types of such screws, and "exposed screw heads were also rejected because pliers could be used to rotate the screw."

You have enclosed a drawing showing a horizontal alignment system that you propose to use. It "would be used during manufacturing to achieve proper mechanical alignment of the mounting surface and lamp optical system and is not meant to be adjustable after manufacture." The drawing you enclose shows both a plan and section view of your system. There is an "external shroud [which] prevents adjustment by wrenches and pliers." There is also a center section described as "center anti-tamper post [which] prevents entry of standard Torx driver bit, screw driver, & Allen wrench." You ask whether we would regard this as a horizontal adjustment mechanism as prohibited by S7.8.2.1(c).

Yes, we would regard this design as a horizontal aim mechanism within the meaning of S7.8.2.1(c)(and impermissible because it does not meet S7.8.5.2). Although the center anti-tamper post prevents entry of a standard Torx driver bit, non-standard Torx driver bits are readily available which would defeat your intent that the horizontal alignment not be adjustable after manufacture. Specifically, SK Drive Tamper-Proof Torx Bits are available through internet web sites, if not tool jobbers and mobile tool sales outlets, and these are intended to fit the center anti-tamper post and allow entry.

If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/28/99

ID: nht69-2.44

DATE: 12/11/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Chrysler Corporation

TITLE: FMVSR INTERPRETATION

TEXT: RE: CONSUMER INFORMATION

We have received your submittal of consumer information in response to the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.

Each of the three substantive sections establishing requirements for Vehicle Stopping Distance, Tire Reserve Load, and Acceleration and Passing Ability respectively specify that the information shall include, "in essentially the form illustrated in Figure 1," a description of the vehicles to which the table applies. Each of the figures in the regulations shows the vehicle description in close proximity to be tables. This element is missing from your compilation of information. Instead you have provided a master key in the front of the booklet, applying to all the tables within. Not only does this not satisfy the requirement in respect to form, but we have found in attempting to transcribe the information into a standard format that it is very difficult to interpret in some cases; and would surely cause confusion to consumers attempting to use it.

We will be glad to answer any questions that you may have with respect to the requirements of these or other motor vehicle safety regulations and standards.

ID: nht71-5.36

DATE: 12/30/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Latham & Watkins

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 16, 1971, in which you ask whether a manufacturer may add certain statements to the Certification label required pursuant to Part 567 of Title 49, Code of Federal Regulations. You state that the manufacturer in question is engaged in the manufacturer and mounting of concrete mixer assemblies. Because, as you state, the weight of the concrete may vary according to the mix formula, and because the volume of mix loaded into a mixer can also vary, the manufacturer wishes to add to his Certification label a declaration of the vehicle's cargo load and an indication of the maximum volume of mix that could be safely hauled within the rated cargo load limit.

There is no prohibition to this additional information being added to the Certification label as long as (1) it appears after the required information, and (2) it is stated in such a way that it cannot be confused with the information, particularly the GVWR and GAWR, required to be placed on the label.

We are pleased to be of assistance.

ID: nht92-4.35

DATE: August 17, 1992

FROM: Spencer A. Darby -- Vice President - Engineering, Sate-lite Mfg. Co.

TO: Legal Counsel - FMVSS 125 -- NHTSA

COPYEE: Larry Michelson

TITLE: None

ATTACHMT: Attached to letter dated 10/28/92 from Paul Jackson Rice to Spencer A. Darby (A40; Std. 125)

TEXT:

IN THE "S1. SCOPE" AND "S3. APPLICATION" SECTIONS OF FMVSS 125, REFERENCE IS MADE TO "...DEVICES, WITHOUT SELF-CONTAINED ENERGY SOURCES,...".

I AM RESPECTFULLY REQUESTING AN AGENCY INTERPRETATION OF THIS PHRASEOLOGY IN REGARDS TO ONE PUTTING FLASHING, BATTERY OPERATED LIGHT SOURCES BETWEEN THE REFLEX REFLECTORS PORTION OF AN OTHERWISE COMPLYING WARNING DEVICE. WOULD THIS ALTERED DEVICE BE IN COMPLIANCE WITH THE FMVSS 125 STANDARD IF THE LIGHT SOURCES WERE OPERATED AFTER DARK? OR, PHRASED ANOTHER WAY, DOES FMVSS 125 APPLY TO AN OTHERWISE COMPLYING DEVICE THAT HAS FLASHING LIGHTS IN IT, AND, IF NOT, WOULD A VEHICLE WHICH IS REQUIRED TO HAVE THE THREE 125 WARNING TRIANGLES HAVE TO HAVE THREE NON-LIGHTED COMPLYING TRIANGLES SET OUT AS WELL?

IT IS OUR OPINION THAT FLASHING LIGHTS IN AN OTHERWISE COMPLYING EMERGENCY WARNING TRIANGLE ENHANCES THE ATTENTION GRABBING CAPABILITY OF THE DEVICE AFTER DARK.

PLEASE FEEL FREE TO TELEPHONE THE WRITER AT ANY TIME, IF HE COULD BE OF FURTHER ASSISTANCE IN CLARIFYING THIS REQUEST FOR AN INTERPRETATION.

ID: nht72-5.9

DATE: 04/08/72

FROM: JOSEPH R. GORMAN FOR FRANCIS ARMSTRONG -- NHTSA

TO: Strick Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 25, 1972, enclosing sample certification labels and requesting our review and comments. The labels you have submitted follow correspondence to you from NHTSA dated February 18, 1972, wherein we disapproved an earlier format you wished to use. Your revised label consists of multiple listings using punched holes and overlays to indicate appropriate information.

We do not consider your revised label to be completely consistent with the Certification regulations (Part 567) in that the information is still presented in a way that is somewhat (and we might add unnecessarily) confusing. This confusion occurs because you do not fully delete information that is inapplicable to the vehicle in question. For example, regarding GVWR and GAWR in samples 2 and 3, you do not delete the entire number (leaving the zeroes and the suffix, lbs.) and it is not clear, in our view, whether the figures have been deleted or whether the label is disfigured. We believe the entire figure should be delted where it is not applicable. Similarly, in the case of month and year, and vehicle number, all the information you wish to omit should be completely deleted. This would require deletion of all months other than the month of manufacture and all numbers other than the vehicle number.

Finally, in using an overlay (sample 4), the overlay should be done in such a manner that the label does not give the appearance of having been tampered with.

We trust this clarifies the situation.

ID: nht78-2.33

DATE: 05/31/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Ward Industries Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your April 27, 1978, letter asking whether a sample certification label that you submitted complies with the National Highway Traffic Safety Administration's (NHTSA) Part 567, Certification.

Military vehicles are exempted from compliance with Federal safety standards. Therefore, the application of the safety standards to these vehicles is a matter of contract between a manufacturer and the military. Since the NHTSA does not mandate Federal safety standards for these vehicles, it is not necessary to put certification labels on them. If you choose to include a label with a vehicle, the label would not be required to comply with any Federal regulations.

ID: nht72-6.47

DATE: 10/05/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Gislaved

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of September 21, 1972, in which you inquire about the use of the third grouping of characters in the tire identification number required by Regulation Part 574.

You are correct in your understanding that there has been no recent change in the regulation regarding the optional use of the third grouping for tire type (Illegible Word) purposes. The third grouping may be used by the manufacturer if he so desires to identify significant characteristics of the tire and he may use up to four symbols in the group. However, if the tire is manufactured for a brand name owner, the third grouping must be used to identify the brand name owner. The tire type code is not compulsory except to identify a brand name owner.

Apparently the organization that uses the enclosure accompanying your letter is making (Illegible Words) within its own operations of using a 10 character identification number even though the regulation does not make it mandatory. The National Highway Traffic Safety Administration has no objection to this practice.

We appreciate your concern for compliance with the regulation. Please let us know if we can be of further assistance.

ID: nht75-2.38

DATE: 08/11/75

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

TO: The Budd Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 8, 1975, asking which standards might be affected by the mounting of a tail lamp in the elastic skin of a bumper.

Motor Vehicle Safety Standard No. 215, Exterior Protection, prescribes barrier and pendulum impact tests to which vehicles must be subjected without incurring certain types of damage. Included in the list of safety systems that must remain undamaged are lamps and reflective devices. S5.3.1 of Standard 215 states that each lamp or reflective device, except license plate lamps, must remain free of cracks and comply with the applicable visibility requirements of S4.3.1.1 of Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The manufacturer should be aware that placement of a tail lamp in the elastic skin of a bumper might expose it to damage during Standard 215 compliance testing.

For your information, I have enclosed copies of the current Standard No. 215, the proposed Part 580 bumper damageability standard, and Standard No. 108.