ID: nht87-1.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of November 21, 1986, with reference to the distance between a front turn signal lamp and a lower beam headlamp.

In brief, SAE Standard J588e, incorporated by reference in Standard No. 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lo wer bean headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.

We concur with your interpretation. Of the two options, the distance to the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's bean, has mo significant luminance, and therefore will not mask the turn signal.

Sincerely,

Erika Z. Jones Chief Counsel

November 21, 1986

Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Distance between a front turn signal lamp and a low beam headlamp)

In Motor Vehicle Safety Standard N0.108, Paragraph 4.3.1.7, the following is prescribed:

S4.3.1.7 The requirement that there be not less than 4 inches between a front turn signal lamp and a low beam headlamp, specified in SAE Standard J588e, "Turn Signal Lamps," September 1970, shall not apply if the sum of the candlepower values of the turn signal lamps Measured at the test point within each group listed in Figure 1c is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.

According to the SAE Standard J588e, the distance is defined as from the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This definition applies only to a standardized headlamp. What definition is appropriate for a replaceable bulb headlamp, in other words, an unstandardized headlamp? We think B in the following definition is appropriate.

A : From the filament center of the front turn signal lamp to the outer edge of a low beam headlamp

B : From the filament center of the front turn signal lamp to the end of the effective area of the reflector of a low beam headlamp

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

ID: nht78-4.11

DATE: 10/31/78

FROM: AUTHOR UNAVAILABLE; S. P. Wood for J. J. Levin, Jr.; NHTSA

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 6, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the "N" dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.

You further advised that the proposed design would not interfere with the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.

Since Figure 8(B) of SAE J571d shows that the "K" dimension shall not exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.

SINCERELY,

TOYOTA MOTOR SALES, U.S.A., INC.

September 6, 1978

Joseph Levin Office of the Chief Council NHTSA

RE: Interpretation Request of FMVSS 108

Dear Mr. Levin:

This is to request your interpretation of SAE J 571d with regard to the retaining ring for 4 x 6 1/2 inch rectangular headlamps, as quoted in FMVSS 108, "Lamps, Reflective Devices, and Associated Equipment."

According to Fig. 8 (B) of SAE J 571d, the forward portion of the retaining ring from the lens surface is limited to 1.52mm ("K" MAX). However, we feel that as long as the performance requirements specified in SAE J 580 a and b, and the aiming requirements specified in SAE J 602c are conformed (Illegible Word), it is not necessary to restrict "K" MAX to 1.52mm.

We are planning to introduce some models with 4 x 6 1/2 inch rectangular headlamps in the near future. The retaining ring is extended ahead, and is formed into a part of the ornamental door or bezel. (See attached drawing.) This retaining ring, as illustrated, is designed so that the opening dimension "L" must comply with the dimension required by the applicable SAE J 571d, "Dimensional Specifications for Sealed Beam Headlamp Unit." The ring's frame portion "M," which is relatively wider in flatness, as indicated, is made to be securely fitted with an aimer specified in SAE J 602c, "Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Unit," when the headlamps are mechanically aimed.

This headlamp housing can fully comply with the requirements of functional performance (such as headlamp aiming adjustment, vibration resistance, and so on) specified in the applicable SAE J 580 a and b, "Sealed Beam Headlamp assembly," as referred to in the current FMVSS No. 108.

We would appreciate your interpretation of this information at your earliest possible convenience.

TOYOTA MOTOR SALES, U.S.A., INC.

M. YANADA for J. Kawano Director/General Manager Factory Representative Office

cc: M. V. ELLIOTT, OFC. OF VEHICLE SAFETY STANDARDS, NHTSA

Attached Drawing

4 x 6 1/2 in. Rectangular Headlamp Retaining Ring

(Dimension: mm)

Retaining ring extended to a part of ornamental bezel

Note: "L": 92.98 +/- 1.30X133.42 +/- 1.30 (SAE required dimension)

(Graphics omitted)

ID: Koito.2

Mr. Takayuki Amma
Manager, Regulations & Certification
Koito Manufacturing Co., Ltd.
4-8-3, Takanawa
Minato-ku Tokyo
Japan




Dear Mr. Amma:

This responds to your recent letter, in which you asked whether it would be permissible under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment, to manufacture and sell a headlamp that automatically reduces intensity when the vehicle is stopped. Your letter stated that the lamp (which includes a fail-safe performance feature) would operate at full intensity when the vehicle is in forward motion, but that an electronic light source control gear would reduce the intensity once the vehicle comes to a rest. According to your letter, "[a]t all times through the change of the intensity, the lamps provide sufficient level of intensity and will be within the parameters of the minimum and maximum values of candela specified in FMVSS No. 108," and you further suggested that such headlamps would have the potential for significant energy conservation (about a 20-40% reduction in wattage), depending upon the optical design of the headlamps. As discussed below, we believe that the intensity-reducing headlamps described in your letter would not be permissible under FMVSS No. 108, because the would not meet the "steady-burning" requirement of S5.5.10.

By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. It is the responsibility of manufacturers to certify that their products conform to all applicable safety standards before they can be offered for sale (see 49 CFR Part 571). After the first sale of the vehicle, manufacturers, distributors, dealers, and repair businesses are prohibited from "knowingly making inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable standard.49 U.S.C. 30122.

As you are aware, the requirements for lighting equipment are contained in FMVSS No. 108, which provides in relevant part:

S5.5.10 The wiring requirements for lighting equipment in use are:
(a) Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall be wired to flash;
(b) Headlamps and side marker lamps may be wired to flash for signaling purposes;
(c) A motorcycle headlamp may be wired to allow either its upper beam or its lower beam, but not both, to modulate from a higher intensity to a lower intensity in accordance with section S5.6;
(d) All other lamps shall be wired to be steady-burning.

In short, S5.5.10(d) of FMVSS No. 108 requires that all lamps must be "steady burning," unless otherwise permitted, and while S5.5.10(b) does permit headlamps to be wired to flash for signaling purposes, we note that paragraph S3 of FMVSS No. 108 defines "flash" as meaning "a cycle of activation and deactivation of a lamp by automatic means."

Your proposed headlamp would not fall within any of the standards express exceptions, and therefore, must be "steady-burning." Through our interpretations, we have explained that the "steady-burning" requirement under the standard means "a light that is essentially unvarying in intensity" (see e.g., February 9, 1982, letter of interpretation to Dr. H.A. Kendall). However, as stated in your letter, your proposed headlamp would routinely experience perceptible intensity changes resulting in a 20-40% reduction in wattage, so the lamp would not meet above definition of "steady-burning."

There are several reasons for the requirement for headlamps to be steady-burning. For example, several States have expressed concern that lights of variable intensity could be confused with emergency vehicles, which are allowed to have flashing headlamps. We also note that motorcycle headlamp modulation, while permitted under S5.5.10(c), must meet the requirements of S7.9.4; the modulation rate is regulated to prevent seizures in susceptible individuals. Furthermore, we believe that motor vehicle safety is best promoted by standardization of lighting signals.

In your letter, you pointed to our July 21, 1998, letter of interpretation to Mr. Ian Goldstein in support of your position that Standard No. 108 should permit headlamps that reduce intensity when stopped. The letter to Mr. Goldstein discussed "gradational" daytime running lamps (DRLs), devices that are capable of modulating the intensity of the DRLs according to ambient light conditions. You quoted from the portion of that letter which provides, "The standard does not prohibit changes in intensity, which we presume will be within the parameters of the minimum and maximum values of candela specified".However, your letter omitted the immediately preceding sentence, which provided, "A DRL with a gradational feature would continue to provide the steady-burning light that is required for DRLs".

The situation presented in your letter is distinguishable from the one presented in our letter to Mr. Goldstein. In the case of gradational DRLs, the lamps would be expected to determine an appropriate level of intensity based upon ambient lighting conditions and then maintain that level until conditions had changed sufficiently to potentially warrant a further change in intensity. In that case, intensity changes would be expected to occur infrequently and could occur gradually, such that the change would not be perceptible to oncoming drivers.

In contrast to gradational DRLs, the changes in intensity that would accompany your proposed headlamp design would be anticipated to result in frequent modulation, particularly during instances of stop-and-go city driving. Assuming that the intensity change is perceptible, we believe that such a design could be a source of distraction to other drivers, which could have negative consequences for safety. Accordingly, we believe that the headlamp design presented in your letter would not meet the requirements of S5.5.10 of FMVSS No. 108.

If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.8/1/05

ID: aiam5544

Dear Mr. Mack: This is in reply to your letter of April 24, 1995 requesting a confirmation of your interpretation that 'Philips Color Clear (TM) Halogen Headlights . . . are in compliance with FMVSS-108.' The product in questions 'appears to be colored when not in use' but 'when lighted it produces white light as defined by J579C.' You have provided a report from ETL Testing Laboratories which 'indicates that the color of the light is identical to that of a standard halogen headlight.' There is no definition of white light in SAE J579c Sealed Beam Headlamp Units for Motor Vehicles, December 1978. We believe you mean SAE J578d Color Specification for Lighting Devices, September 1978 which does contain a definition expressed in chromaticity coordinates. The report you supplied indicates that the Philips lamp provides a light within the color coordinates for white when equipped with a red, black, blue, or white insert. As Standard No. 108 contains no requirements for the color of glass lamp lenses or bulbs, only the light emitted from the lamp, we confirm your conclusion that the Philips Color Clear (TM) headlamp has been designed to conform to the color requirements of Standard No. 108. We appreciated your visit to NHTSA on April 26 to demonstrate the lamp with its various inserts. I understand that the light produced by the lamp, and by a standard headlamp, appeared identical to the naked eye in a side by side comparison. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel;

ID: aiam4475

Dear Mr. Kadoya: This is in reply to your letters of July 14, l988 with respect to an interpretation of Motor Vehicle Safety Standard No. 108 and a request for confidential treatment of it. We understand that you orally withdrew this request during a telephone conversation with this Office on August 23, l988. You have asked whether Standard No. 108 permits the use of replaceable bulb headlamps with adjustable reflectors, or the use of such lamps as fog and/or cornering lamps. Although Standard No. 108 defines a replaceable bulb headlamp as one with a bonded lens-reflector assembly, this definition does not preclude a design with an adjustable reflector, as the bond may be applied to a portion of the reflector assembly that is not adjustable. However, a headlamp with an adjustable reflector must be designed to conform with all applicable photometric requirements with the reflector in all positions in which it may be adjusted. As for its use as a fog or cornering lamp, you are correct that it is acceptable provided that it does not impair the effectiveness of the lighting equipment required by Standard No. 108. Whether the device impairs the effectiveness is determined by the vehicle manufacturer before it certifies compliance with all applicable Federal motor vehicle safety standards. The decision, however, may be questioned by this agency if it appears erroneous. I hope that this answers your questions. Sincerely, Erika Z. Jones Chief Counsel;

ID: 21078.ztv

M. Guy Dorleans
International and Regulatory Affairs Mgr.
Valeo
34 rue Saint-Andre
93012 Bobigny
France

Dear M. Dorleans:

This is in reply to your letter of December 17, 1999, asking for confirmation that a new headlamp design is in conformance with Federal Motor Vehicle Safety Standard No. 108.

The headlamp incorporates three replaceable light sources. The upper beam is provided by two bulbs called "HB nb1" and "HB nb2." The lower beam is also provided by two bulbs, the first being "LB nb1" (the same bulb as "HB nb1") and by bulb "LB nb2." The headlamp meets the photometric requirements of Table 17-2 in each beam mode.

Paragraph S4 Definitions of Standard No. 108 defines a "replaceable bulb headlamp" in pertinent part as "a headlamp comprising . . . one or two replaceable light sources . . . ." Because the Valeo design incorporates three replaceable light sources, it does not comply with the definition, and thus is not a replaceable bulb headlamp design allowed by Standard No. 108.

We are, however, considering amending the definition of "replaceable bulb headlamp" to allow more than two light sources. On November 12, 1998, we proposed a revision of Standard No. 108 (63 FR 63258). With respect to proposed S7.4.5 Arrangement and marking of upper and lower beams, and S7.5.3 Arrangement and marking of upper and lower beams, we remarked (at 63260) that these paragraphs anticipate "future headlamp designs with an array of light sources . . . ." But we overlooked proposing a corresponding amendment to "replaceable bulb headlamp" which would define it as comprising one or more light sources. Because the proposal presented the issue of multiple-bulb replaceable bulb headlamps, we will consider for purposes of a final rule including a redefinition of "replaceable bulb headlamp" that would accommodate headlamps such as Valeo's. We plan to announce a decision during 2000.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/10/2000

ID: 2781y

Mr. Gordon Bonvallet
1686 Lighthouse Hill Road
Homer, NY 13077

Dear Mr. Bonvallet:

This is in reply to your letter of October 5, l990, with respect to a prospective headlighting system. It is contemplated that the lower beam on the system would be furnished by a gaseous discharge headlamp, an "integral beam" headlamp under Standard No. l08. The upper beam would be furnished by a replaceable bulb headlamp using an HB3 light source.

You comment that a combination system such as this is not specifically addressed by Standard No. l08, and you ask for confirmation of your opinion that the photometric requirements of Figure l5 would apply to both the upper and lower beam headlamps.

At the present time, such a hybrid headlighting system is impermissible under Standard No. l08. The standard establishes separate requirements for integral beam headlighting systems (S7.4), and for replaceable bulb headlighting systems (S7.5). Though "integral beam headlighting system" is not specifically defined by Standard No. l08, such a system would appear to be one that consists of integral beam headlamps. Standard No. l08 does define "integral beam headlamp", and that definition specifically excludes "a replaceable bulb headlamp" such as one containing an HB3 light source. Similarly, a "replaceable bulb headlamp system" is one that consists solely of headlamps containing HB1, HB2, HB3, HB4, or HB5 light sources.

It is true that Figure l5 is one of three lower beam photometric options that apply to an integral beam headlamp, such as one producing illumination through gaseous discharge. However, under the language of the standard, Figure l5 applies when the lamp is used in a four headlamp integral beam headlighting system (S7.4(a)(l)(i)). It is also true that the upper beam photometrics of Figure 15 apply to an HB3 replaceable bulb headlamp (S7.5(e)(3)(ii)), but only when used in a four lamp headlighting system in which each headlamp contains a single replaceable light source.

As you know, the policy of this agency for the last decade has been to reduce design restrictions on headlighting systems. Removal of the implicit prohibition against hybrid headlighting systems would be a further step in this direction. If your client is seriously considering such a system, it may submit a petition for rulemaking at the appropriate time.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:12/24/90

ID: nht90-4.92

TYPE: Interpretation-NHTSA

DATE: December 24, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Gordon Bonvallet

TITLE: None

ATTACHMT: Attached to letter dated 10-5-90 from Gordon Bonvallet to Paul Jackson Rice (OCC 5282)

TEXT:

This is in reply to your letter of October 5, 1990, with respect to a prospective headlighting system. It is contemplated that the lower beam on the system would be furnished by a gaseous discharge headlamp, an "integral beam" headlamp under Standard No . 108. The upper beam would be furnished by a replaceable bulb headlamp using an HB3 light source.

You comment that a combination system such as this is not specifically addressed by Standard No. 108, and you ask for confirmation of your opinion that the photometric requirements of Figure 15 would apply to both the upper and lower beam headlamps.

At the present time, such a hybrid headlighting system is impermissible under Standard No. 108. The standard establishes separate requirements for integral beam headlighting systems (S7.4), and for replaceable bulb headlighting systems (S7.5). Though " integral beam headlighting system" is not specifically defined by Standard No. 108, such a system would appear to be one that consists of integral beam headlamps. Standard No. 108 does define "integral beam headlamp", and that definition specifically ex cludes "a replaceable bulb headlamp" such as one containing an HB3 light source. Similarly, a "replaceable bulb headlamp system" is one that consists solely of headlamps containing HB1, HB2, HB3, HB4, or HB5 light sources.

It is true that Figure 15 is one of three lower beam photometric options that apply to an integral beam headlamp, such as one producing illumination through gaseous discharge. However, under the language of the standard, Figure 15 applies when the lamp is used in a four headlamp integral beam headlighting system (S7.4(a)(1)(i)). It is also true that the upper beam photometrics of Figure 15 apply to an HB3 replaceable bulb headlamp (S7.5(e)(3)(ii)), but only when used in a four lamp headlighting system in which each headlamp contains a single replaceable light source.

As you know, the policy of this agency for the last decade has been to reduce design restrictions on headlighting systems. Removal of the implicit prohibition against hybrid headlighting systems would be a further step in this direction. If your client is seriously considering such a system, it may submit a petition for rulemaking at the appropriate time.

ID: nht89-2.26

TYPE: INTERPRETATION-NHTSA

DATE: 07/05/89

FROM: JEFFREY R. MILLER -- NHTSA ACTING ADMINISTRATOR

TO: FRED GRANDY -- HOUSE OF REPRESENTATIVES

TITLE: NONE

ATTACHMT: LETTER DATED 05/09/89 FROM FRED GRANDY -- CONGRESS TO JERRY CURRY -- NHTSA; LETTER DATED 05/05/89 FROM DANIEL F. WIECHMANN TO ROBERT A. DETERMAN, RE THE STATE OF IOWA VS. BARRY LYNN SPEICH; LETTER DATED 09/23/88 FROM DANIEL F. WIECHMANN TO RUTH SKLUZACEEK, RE THE STATE OF IOWA VS. BARRY LYNN SPEICH, FRANKLIN COUNTY CRIMINAL NO. WD488435; NO 24.432.0788 [321.424] OF THE CODE OF IOWA; LETTER DATED 10/10/88 FROM JODY JOHNSON -- IOWA DOT TO DANIEL F. WIECHMANN, REF NO 911.2; LETTER DATED 10/14/88 FROM DANIEL F. WIECHMANN TO RALPH HITCHCOCK -- NHTSA, RE THE STATE OF IOWA VS. BARRY LYNN SPEICH, FRANKLIN COUNTY CRIMINAL NO WD488435; NO. 24.432.0788 [321.424] OF THE CODE OF IOWA

TEXT: Dear Mr. Grandy:

This is in reply to your recent letter to the Administrator Designate, Jerry Curry, on behalf of your constituent Daniel Weichmann, Jr., of Hampton. You enclosed a copy of Mr. Weichmann's letter to this agency with respect to headlamp covers which, regr ettably, we have been remiss in answering. You asked that we review this matter and that you be provided a copy of our response. We are pleased to reply directly to you, with a copy to Mr. Weichmann so that he may be apprised immediately of our views.

Mr. Weichmann was advised by the Iowa Department of Transportation on October 10, 1988, that "The department specifically does not approve head lamp covers", because Iowa has adopted "Federal standards on equipment approval". Consequently, "If the headla mp covers in question meet the Federal Standards they would qualify under Iowa law." Thus, Mr. Weichmann asked us whether headlamp covers are approved by this agency.

Headlamp covers are not permissible as items of original motor vehicle equipment. Paragraph S7.7.5 of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, in pertinent part, states that when headlamps are o perated they "shall not have any styling ornament or other feature, such as a translucent cover or grill, in front of the lens." Although Standard No. 108 was only recently amended to state this prohibition expressly (I enclose a copy of the amended stan dard), the prohibition has existed since January 1968 through the incorporation by reference in Standard No. 108 of an SAE headlamp Standard, J580b, which contained the identical language. The safety reason for the prohibition is the reduced effectivene ss of a headlamp beam when it must pass through an extra layer of glazing, particularly if that glazing is tinted, yellowed, or cracked, or if moisture has condensed on the inside of the cover. Thus, headlamp covers are also implicitly prohibited by par agraph S5.1.3 of Standard No. 108 which forbids the installation of optional equipment that impairs the effectiveness of lighting equipment, such as headlamps, that are required by Standard No. 108.

The Iowa DOT's views are consistent with the provisions of the National Traffic and Motor Vehicle Safety Act which permit States to enact State

motor vehicle safety standards applicable to new vehicles provided that they are identical to Federal ones covering the same aspect of performance. Although the Federal standards do not regulate operation of a vehicle after it is sold, and hence cou ld not prohibit a vehicle owner in Iowa from installing headlamp covers and operating his vehicle with them, Iowa's enforcement of a headlamp cover prohibition for vehicles in use would be consistent with its prohibition of them as original vehicle equip ment. However, we cannot interpret Iowa law, and reach no conclusion as to whether its statutes or regulations have that effect.

Should either you or Mr. Weichmann have further questions, we shall be pleased to answer them.

Sincerely,

ENCLOSURE

ID: nht88-1.81

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/88

FROM: DON O. HORNING -- P. E. INDUSTRIAL TESTING LABORATORIES

TO: C-MORE-LITE, JERRY'S SERVICE

TITLE: TEST REPORT NO: 92606

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DOUGLAS H BOSCO, FROM ERIKA Z JONES, REDBOOK A32 (2) STANDARD 108 LETTER DATED 06/16/88, TO ERIKA Z. JONES, FROM DOUGLAS H. BOSCO; LETTER DATED 08/03/87 TO DOUGLAS H. BOSCO FROM ERIKA Z JONES; LETTER DATED 0 6/09/88 TO JERRY K YOST FROM L. FROLLIN; 1988 LETTER TO ERIKA Z. JONES FROM JERRY SERVICE

TEXT: Enclosed is the photometric data taken on the Halogen H4651 Single Filament Sealed Beam Headlamp and the Halogen H4656 Dual Filament Headlamp.

The two headlamps were mounted on a standard text fixture placed on the goniometer and aimed per specification SAE J579, Dec 84. Candlepower readings were taken at the appropriate settings with both filaments energized on the H4656 headlamp and with the single filament energized on the H4651 headlamp.

These readings were combined to simulate the operation of the C-More-Lite Headlight relay which activates both filaments on the 2-filament headlamp as well as the single filament to effectively provide both low beam and high beam illumination when the hi gh beam is switched on.

The accompanying table of photometric results at 100 ft were made with the aim established per SAE J579, Dec 84, Section 3.4 and the voltage at 12.8 volts. As indicated at the bottom of the table, the maximums could not be combined, as they did not coin cide as to location. Adjusting either lamp to the location of the other maximum did not produce a combined maximum in excess of the permissible maximum of 75,000 cd.

No tests were run utilizing the C-More-Lite relay in the circuit. tests run only simulate the effect of its operation.

As a part of this report a copy of SAE J579, Dec 84, is included for substantiation of test points and maximum and minimum cd. There is also included a diagram of the measurement points combining both upper and lower beams.

It should be noted that this laboratory takes no position relative to the C-More Relay as regards its utilization.

Description of Headlamps used: ITL TEST NUMBER 92606

1. Lamp Halogen H4651 - 4x6 1/2 inch sealed beam headlamp Westinghouse Headlamps by Philips (Assembled in Mexico) High Beam for 4 head light system Replaces 4651, HP4651 2 lugs - 12 volts Marked - 1A1 Sealed Beam, Halogen, U.S.A. DOT.

2. Lamp Halogen H4656 - 4x6 1/2 inch sealed beam headlamp Westinghouse Headlamps by Philips (Assembled in Mexico) Low Beam for 4 headlamp system Replaces 4656, HP4656 3 lugs - 12 volts Marked - 2A1 Sealed Beam, Halogen, U.S.A. DOT.

[TABLE OF PHOTOMETRIC TESTS H4656 AND H4651 SEAL BEAM HEADLAMPS, ITL TEST NO 92606, OMITTED]

[SAE J579 STANDARD OMITTED]

LOWER BEAM & UPPER BEAM (CHART OMITTED)