NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam5462OpenMr. Bryan J Williams Director, International Operations Red Spot Paint & Varnish Co Inc. 1111 East Louisiana Street Evansville, IN 47711; Mr. Bryan J Williams Director International Operations Red Spot Paint & Varnish Co Inc. 1111 East Louisiana Street Evansville IN 47711; "FAX 812-467-2388 Dear Mr. Williams: This is in reply to your FAX o October 24, 1994, to Taylor Vinson of this Office requesting an interpretation regarding the relationship of Motor Vehicle Safety Standard No. 108 to an AAMVA list. Your company manufactures UV coatings for polycarbonate headlamp lenses. These 'provide abrasion resistance properties as well as protecting the plastic lens from the deleterious effects of outdoor exposure.' One of these coatings, UVT200, is used by Ford, General Motors, and Chrysler on headlamp lenses. However, 'UVT200 does not appear on the American Association of Motor Vehicle Administrators (AAMVA) 'Listing of Acceptable Plastics for Optical Lenses and Reflectors Used on Motor Vehicles.'' You inform us that some overseas headlamp manufacturers believe that appearance on the list is required by Federal law and is a prerequisite to certification. The question you ask is: Must a coating for plastic (polycarbonate) headlamp lenses appear on the AAMVA 'Listing . . .' in order to meet the requirements of FMVSS 108? The answer is no. Paragraph S5.1.2 of Standard No. 108 requires that plastic materials used in lenses (which include headlamp lenses) conform to SAE Recommended Practice J576c, Plastic Materials for Use in Optical Parts, Such as Lenses and Reflectors of Motor Vehicle Lighting Devices, May 1970. Under SAE J576c's outdoor exposure test, the luminous transmittance of the material must not change by more than 25% from its performance before the test. In appearance, the headlamp lens material must not show surface deterioration, crazing, dimensional changes, or delamination. Also, under paragraph S5.1.2(b), after the outdoor exposure test, the haze and surface luster of the material must not be greater than 30 percent haze, as measured by ASTM D-1003-61. Manufacturers have found that a coating is required for the plastics used in headlamp lenses to meet Standard No. 108's outdoor exposure requirements. However, neither SAE J576c or Standard No. 108 require the coating, let alone specify what coating is acceptable. The decision to coat, and the choice of coating, is that of the manufacturer in determining compliance with and certification to Standard No. 108. Therefore, the AAMVA list has no legal relationship to Standard No. 108 and it is immaterial to NHTSA whether the coating used is or is not on the AAMVA list. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam4964OpenHerrn. Westermann u. Schmidt Hella KG Hueck & Co. Rixbecker Stra e 75 Postfach 2840 4780 Lippstadt Germany; Herrn. Westermann u. Schmidt Hella KG Hueck & Co. Rixbecker Stra e 75 Postfach 2840 4780 Lippstadt Germany; "Gentlemen: This responds to your FAX of December 9, 1991, to Richar Van Iderstine of this agency. You ask for a definition of two and four headlamp systems, stating that formerly 'this definition was done under para. S4.1.1.36, but today there only remains figure 26, which explains the application of photometric requirements with respect to the bulb or bulb combination used.' You have enclosed sketches of three replaceable bulb headlighting systems and ask for confirmation that each is a two or four headlamp system under Standard No. 108. Standard No. 108 has never contained a specific definition of two or four lamp headlamp systems. Paragraph S4.1.1.36 impliedly defined these systems for headlamps incorporating replaceable bulbs by specifying requirements for the upper and lower beams of headlamp systems consisting of two or four lamps, each containing one or two standardized replaceable light sources. When Standard No. 108 was amended to delete S4.1.1.36, these provisions became part of new paragraph S7.5 Replaceable Bulb Headlamp System. Figure 26 Table of Photometric Requirements was added to illustrate photometric requirements for headlighting systems that use combinations of replaceable bulbs listed in S7.6 Standardized Replaceable Light Sources, and as the systems are described in S7.5. The understanding expressed in your drawings of replaceable bulb headlamp systems is correct. A 4-lamp system is one in which each lamp contains one light source, usually HB3 or HB4 light source for a total of two HB3 and HB4 light sources per system. A 2-lamp system is one in which each lamp typically contains a single dual filament light source such as HB1 or HB5, and achieves both a lower beam and an upper beam, alternatively, each lamp may contain two light sources, typically one HB3 and one HB4 light source, each with individual reflectors, but together with a common housing and lens. This lamp achieves both a lower and an upper beam. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam4408OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; 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 September 18, 1987, with respect t a new headlamp design of very low profile. The height of the headlamp is less than that required by dimension A of Figure 4, of Standard No. 108, and you have asked NHTSA: 'to make the height of the headlamp lower than dimension A...on condition that the additional adaptor will be provided as original equipment'.; You are under the impression that our interpretation to you dated Marc 26, 1987, relating to acceptability of a headlamp lens with a 60 degree angle was an affirmative one conditioned upon the provision of an adaptor as original equipment. In fact, we only advised you that such an adaptor should be provided, not that it was required. With respect to your present letter, dimension A is established by Standard No. 108 and cannot be modified except through rulemaking, whether or not an adaptor is provided.; If you wish to submit a petition for rulemaking to amend dimension A o Figure 4 we shall be pleased to consider it. The agency also intends to publish in the near future a Notice asking comments on various aspects of vehicle headlamp aim and aiming methods which you may wish to consider in relation to your new headlamp design.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4850OpenMr. Saburo Inui Corporate Manager Toyota Motor Corporate Services of North America, Inc. 1850 M Street, N.W. Washington, D.C. 20036; Mr. Saburo Inui Corporate Manager Toyota Motor Corporate Services of North America Inc. 1850 M Street N.W. Washington D.C. 20036; Dear Mr. Inui: This responds to your letter of February 20, 1991, wit respect to an interpretation of Standard No. 108 as it relates to High Intensity Discharge Headlamp (HID) designs contemplated by Toyota. You explained these designs in greater detail to NHTSA staff members in a meeting with them on February 20. Standard No. 108 defines an 'integral beam headlamp' as one which is neither a sealed beam headlamp nor one equipped with a standardized replaceable light source, but one which is a 'headlamp comprising an integral and indivisible optical assembly, including lens, reflector, and light source.' You have presented two HID headlamp designs, and have asked whether these lamps are 'integral beam headlamps' as defined by Standard No. 108. These lamps differ from conventional headlamps by having ballast, consisting of a 'starter' affixed to the rear of the headlamp, connected to a 'converter,' which is separated from the headlamp-starter unit. Because of space limitations, it may not be feasible to integrate the ballast into the headlamp enclosure. On one of these headlamps (Figure 2) the starter and converter are directly connected to each other by a 'hard wire' while in the other (Figure 3), the starter and converter are connected by 'hard wires' that meet at a connector between the two. In this design, the ballast units would be installed separately, then permanently joined by a connector, which could not be separated without destroying the connector. You believe that both designs are 'integral beam headlamps.' The phrase 'optical assembly' in the definition of 'integral beam headlamp', in our view, encompasses all lamp components other than the power source which are required for illumination of the headlamp. This means that an 'optical assembly' includes the ballast. Although the lamp, starter, and converter may be permanently attached to each other, and could be considered 'indivisible,' and the starter could be considered to be 'integral' with the lamp body, the positioning of the converter at some distance from the starter, as shown in your Figure 2 and Figure 3, does not render it 'integral' within the meaning of the definition, unless it is permanently attached to the starter. However, a design which had a connector as in your Figure 3 and described in your letter, would be considered both 'integral' and 'indivisible' if its individual components were not permanently attached to each other until the installation of the device in a motor vehicle, providing that any portion of the device could not be subsequently detached without damage sufficient that the entire device would have to be replaced. This would apply to either original or replacement equipment. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam4375OpenMr. William Shapiro, Manager, Regulations and Compliance, Volvo Cars of North America, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulations and Compliance Volvo Cars of North America Rockleigh NJ 07647; Dear Mr. Shapiro: This responds to your letter concerning the Part 581 Bumper Standard You asked whether headlamp washer- wiper systems should be removed from a vehicle prior to testing. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by NHTSA, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements.; Section 581.6 of the Bumper Standard specifies a number of condition which apply to the standard's impact tests. One of these conditions, set forth in paragraph (a)(5), is that '(t)railer hitches, license plate brackets, and headlamp washers are removed from the vehicle.' You stated that the standard was promulgated prior to the advent of headlamp washer-wiper systems, and suggested that the interpretation of 'headlamp washers' can be expanded to include headlamp washer-wiper systems. It is our opinion that for purposes of the Part 581 Bumper (sic) the term 'headlamp washers' is sufficiently broad to include headlamp washer-wiper systems.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4544OpenMr. Byung M. Soh Marketing Director Target Marketing Systems, Inc. P.O. Box 59483 Chicago, IL 60659-0483; Mr. Byung M. Soh Marketing Director Target Marketing Systems Inc. P.O. Box 59483 Chicago IL 60659-0483; Dear Mr. Soh: This is in reply to your letter of June 20, 1988, wit respect to two motor vehicle lighting products which you intend to import into the United States. You have asked 'whether these devices require approvals from D.O.T.' First let me explain that the Department of Transportation does not 'approve' or 'disapprove' specific products. It does advise whether a product appears allowable under the National Traffic and Motor Vehicle Safety Act and the Federal Motor Vehicle Safety Standards. Your letter does not indicate whether you wish to market these devices as original equipment to be installed before initial sale of a motor vehicle, by either its manufacturer or dealer, or whether you intend to market them solely through the aftermarket. I shall address each situation. The Federal motor vehicle safety standard that applies to original equipment is Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Paragraph S4.1.3 of Standard No. 108 allows additional motor vehicle equipment provided that it does not impair the effectiveness of the lamps and reflectors required as original equipment. Effectiveness may be impaired if the device creates a noncompliance in the existing lighting equipment or confusion with the signal sent by another lamp, or functionally interferes with it, or modifies its candlepower to either below the minima or above the maxima permitted by the standard. In addition, a motor vehicle must remain in conformance with Standard No. 108 (and all other safety standards) until its first purchase for purposes other than resale. There is no Federal standard that applies to your devices as aftermarket equipment, but the National Traffic and Motor Vehicle Safety Act prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, original lighting equipment. Your first device is called a 'foglight converter.' The advertising literature attached states that its function is to turn 'the existing headlights...into foglights....' In our opinion, such a device would create a noncompliance with Standard No. 108 by rendering the headlamp function unavailable when the fog lamp converter is in use. We shall assume that the headlamp would be converted into a fog lamp meeting the specifications of SAE Standard J583 May81 Front Fog Lamps. None of the photometric test points of SAE J583 coincide with those specified for headlamps. Our further concern with this device is that a driver might fail to return to the headlamp mode from the fog lamp mode, and operate the vehicle with reduced frontal lighting. The situation differs with respect to the aftermarket. Under the National Traffic and Motor Vehicle Safety Act, a manufacturer, distributor, dealer, or motor vehicle repair business may not perform modifications that render inoperative, in whole or in part, equipment such as headlamps added pursuant to a Federal safety standard. We believe that the installation of the converter could affect the operability of the headlamp within the meaning of the statutory prohibition. However, we note that the foglight converter is advertised as 'easy for any driver to attach to any vehicle.' As an owner is not a manufacturer, distributor, dealer, or motor vehicle repair business, the owner is not restricted under Federal law from modifications to his vehicle. He is, however, subject to the laws of the States in which his vehicle is registered and operated. We are not conversant with how State lighting laws might affect use of the foglight converter, and you may wish to obtain an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. We have several other comments as well. The literature you enclosed depicts the foglight converter attached to what appears to be the European-designed H-4 bulb. Standard No. 108 does not permit headlamps with H-4 light sources to be sold for use on 4-wheeled motor vehicles. In addition, the application of the device where motion is translated from the lamp's exterior to the interior by a linkage in the bulb base would affect compliance with the requirement that the bulb base withstand a pressure differential of l0 psi. Additionally, creating a hole or passage for a linkage has the potential of rendering the headlamp noncompliant with Standard No. 108's requirements for certain environmental tests, such as resistance to dust, corrosion, and humidity. Your second device is a 'headlamp intensity modulator,' adjusting a headlamp beam 'automatically from low to high beam through a middle beam.' According to your literature, when a sensor notes the beams of an oncoming car 500 meters ahead the upper beam gradually passes through a middle beam and diminishes into a lower beam when the vehicles are 150 meters apart. This device is also advertised as capable of owner installation, and without the modification of any vehicle parts. The system appears to operate by a switch. This device directly conflicts with Standard No. 108, and its use would create a noncompliance with it. Headlamps are defined as producing upper and lower beams, and means must be provided for switching between these beams. Use of the device would alter upper and lower beam characteristics from those required by Standard No. 108, and in effect create an infinite number of beams while passing from a conforming upper beam at one extreme to a conforming lower beam at the other. This precludes its use as original equipment. We believe that its aftermarket legality would be limited. Although Federal law would not preclude an owner from installing it, the instructions are sufficiently complex that in our opinion many purchasers would seek help from a 'dealer' or 'motor vehicle repair business,' which could not be legally given. There would also remain the question of legality with State laws. These appear to be innovative devices and we regret that we cannot be more encouraging. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam3757OpenMr. Karl-Heinz Ziwicka, Manager, Safety & Emission Control Engineering, BMW of North America, Inc., Montvale, NJ 07645; Mr. Karl-Heinz Ziwicka Manager Safety & Emission Control Engineering BMW of North America Inc. Montvale NJ 07645; Dear Mr. Ziwicka: This is in reply to your letter of August 4, 1983, to Mr. Vinson o this office asking for reconsideration of our December 8, 1982, letter in which we stated that Motor Vehicle Safety Standard No. 108 prohibits the use of glass or plastic shields in front of motorcycle headlamps. You have pointed out that this appears to reverse a previous interpretation issued by this office on March 15, 1978, in which we concluded that such covers were not precluded.; As is well known, SAE Standard J580 *Sealed Beam Headlamp Assembly precludes the use of covers in front of headlamps in use. Because Standard No. 108 allows installation on motorcycles of half of a passenger car sealed beam headlighting system (principally because SAE J584 allows use of headlamps meeting SAE J579 *Sealed Beam Headlamp Units*), the 1982 interpretation applied the prohibition against covers to all sealed beam headlamps, even those used on motorcycles. With respect to unsealed lamps, the agency cited paragraph S4.1.3, the prohibition against installation of additional equipment impairing the effectiveness of required lighting equipment, and concluded that the possibility of deterioration of light output through cracked or discolored covers precluded covers over nonsealed lamps. On the other hand, the 1978 interpretation concluded that, since the cross referenced J579 did not itself reference J580, the prohibition did not apply.; We have reviewed this matter and have concluded that headlamp cover for motorcycles are not *per se* prohibited by Standard No. 108. As the 1978 interpretation implies, and as you make explicit, the only standard Table III directly incorporates for motorcycles headlamps is J584, whereas J580 is one of several standards directly incorporated for headlamps on four-wheeled vehicles. Nevertheless, we still conclude that these covers are prohibited if they impair the effectiveness of the headlamp.; If, for example, the angle of the cover is so extreme that headlam 'effectiveness' is 'impaired' because of deterioration of the beam, then the manufacturer may wish to remove the shield or redesign it. If, as another example, a plastic cover is intended and a manufacturer has knowledge that it is susceptible to accelerated hazing or cracking, that manufacturer should not use a cover manufactured of this plastic.; In summary, this letter modifies both our 1978 and 1982 opinions b concluding that headlamp covers for motorcycles are permissible if they will not impair the effectiveness of the headlamp.; The agency is reviewing this subject to determine if rulemaking i advisable to prohibit covers of any sort over motorcycle headlamps, similar to the prohibition against such covers on four-wheeled motor vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3928OpenMr. Koji Tokunaga, Manager, Engineering, Isuzu Motors America, Inc., 21415 Civic Center Drive, Southfield, MI 48076; Mr. Koji Tokunaga Manager Engineering Isuzu Motors America Inc. 21415 Civic Center Drive Southfield MI 48076; Dear M. Tokunaga: This responds to your letter concerning an amendment to Federal Moto Vehicle Safety Standard No. 101, *Controls and Displays*, which became effective on an optional basis on July 27, 1984, and becomes effective on a mandatory basis on September 1, 1987. The answers to your questions are provided below.; By way of background information, this agency does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; Your first question asked about the identification requirements for headlamp beam control that is separate from the master lighting switch. You asked how such a control should be identified and whether it is subject to the standard's identification requirements if it controls only the headlamps and not the taillamps. As discussed below, such a control should be identified by either identifying word or identifying symbol, whether or not the headlamp beam control operates the taillamps. The specific word or symbol is at the option of the manufacturer. Additional words or symbols may be provided for purposes of clarity at the discretion of the manufacturer.; Section S5.2.1 states in relevant part: >>>Vehicle controls shall be identified as follows: (a) ... any hand operated control listed in column 1 of Table 1 tha has a symbol designated in column 3 shall be identified by that symbol. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2, if such word abbreviation is shown. Words or symbols in addition to the required symbol, word or abbreviation may be used at the manufacturer's discretion for the purpose of clarity. Any such control for which column 2 of Table 1 and/or column 3 of Table 1 specifies 'Mfr. Option' shall be identified by the manufacturer's choice of a symbol, word or abbreviation, as indicated by that specification in column 2 and/or column 3. The identification shall be placed on or adjacent to the control. The identification shall, under the conditions of S6, be visible to the driver and, except as provided in S5.2.1.1 and S5.2.1.2, appear to the driver perceptually upright.<<<; As your letter noted, controls for 'Headlamps and Taillamps' are amon those listed in column 1 of Table 1. That table specifies that identifying words or abbreviations or identifying symbols are at the manufacturer's option, and includes a footnote stating that separate identification is not required if those lamps are controlled by a master lighting switch. It is our opinion that the term 'Headlamps and Taillamps' includes controls which operate only the headlamps. Therefore, identification in the form of word or symbol must be provided for such a control; Your second question asked about the identification requirements for master lighting switch control for which there are three positions. In the first position, all lights are off, in the second position, all lights are on except for the headlamps, and in the third position, all lights are on. Your question was asked in reference to a drawing showing two types of switches (with two proposed methods of identification for each switch). The first type of switch, which you referred to as a push button switch, consists of three buttons directly adjacent to one another. The second type of switch, which you referred to as a rotary switch, consist of a switch at the end of a stalk, which rotates about the axis of the stalk to provide the three positions. You asked about two alternative interpretations concerning the identification requirements for these controls: (1) whether the master lighting switch symbol must be indicated in the position of the headlamp mode or (2) whether it is instead permissible to use the optional headlamp and taillamp symbol given in Table 1(a) provided that the master lighting switch symbol is affixed nearby. As discussed below, the master lighting switch symbol need not be indicated in the position of the headlamp mode so long as that symbol is on or adjacent to the switch.; Section S5.2.1, quoted above with respect to your first question, i also relevant to this question. Master lighting switches are among the controls listed in column 1 of Table 1, and an identifying symbol is specified by column 3. Under section S5.2.1, therefore, manufacturers must identify master lighting switches by the specified symbol and place the symbol on or adjacent to the master lighting switch. It is our opinion that each of the designs discussed by your letter represents one mater lighting switch, with three positions. Standard No. 101 permits the specified symbol to be placed anywhere on or adjacent to the master lighting switch and does not require the placement of the symbol to indicate the position of the headlamps mode. Manufacturers are not required to provide any identification other than the specified symbol for master lighting switch, it is our opinion that all four designs would be permitted by the standard.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2147OpenRobert S. Raymond, Esq., Assistant Attorney General, Criminal Divison (sic), State of Maine, Department of the Attorney General, Augusta, ME 04333; Robert S. Raymond Esq. Assistant Attorney General Criminal Divison (sic) State of Maine Department of the Attorney General Augusta ME 04333; Dear Mr. Raymond: We have received copies of correspondence between you and Leonard A Fink, Washington counsel for Bombardier/Puch motorized bicycles, concerning requirements of the State of Maine for motor driven cycle headlamps. I understand that Mr. Fink as provided you with a copy of my letter of September 17, 1975 to him. Mr. Fink has asked that I write you directly concerning our views on Federal preemption of State motor vehicle safety standards.; At issue is whether the State of Maine may continue to requir motorcycles of 5 horsepower or less to be equipped with multiple beam headlamps. In my letter to Mr. Fink I stated:; >>>'Any motorcycle with 5 horsepower or less manufactured on or afte January 1, 1969, may be equipped with either a single or multiple beam headlamp (Table III, Standard No. 108, incorporating by reference SAE Standard J584, *Motorcycle and Motor Driven Cycle Headlamps*, April 1964. See Table I of J584. This means, pursuant to 15 U.S.C. 1392(d) that a State is preempted from requiring a motorcycle with 5 horsepower or less to be equipped with a multiple beam headlamp if its manufacturer has equipped it with a single beam one'.<<<; You replied to Mr. Fink on November 7, 1975 that >>>'Table I appears to be inconclusive . . . . The most reasonabl interpretation . . . is that motor driven cycles at high beam frequently utilize both the upper beam of the multiple beam light and a additional single beam light, whereas motor driven cycles at low beam may use the lower beam of the multiple lights (Table II of J584). At any rate, I have not found any clear preemptive language such as we find with regard to turn signal lamps in Standard No. 108 S 4.1.1.26.'<<<; There are actually four different permissible lighting configuration available for motor driven cycles. The 'multiple beam light and an additional single beam light' to which you refer is one of them, specifically the 'one 5 3/4 inch Type 1 and one 5 3/4 inch Type 2 sealed beam units' referred to in SAE J584's *General Requirement*. But the photometrics of Table I do not refer to this configuration, whose photometrics are those of J579. As a practical matter motor driven cycles will rarely if ever be equipped with more than one headlamp because of the severe drain on their low power reserve. In recognition of the limited generating capability of motor cycles with 5 horsepower or less, J584 does allow use of a single beam headlamp as the sole forward lighting source. The texts of the sections on *Beam Aim During Photometric Test* and *At-Focus Tests* refer specifically to test methods for single beam headlamps, and while the standard could be even more specific, its requirements appear to be generally understood by manufacturers and law enforcement officials. It is not a prerequisite for preemption that there be language in the body of Standard No. 108 specifying allowable headlamp systems for motor driven cycles. Where, as here, the area of motor driven cycles. Where, as here, the area of motor driven cycle headlighting is clearly covered by Standard No. 108, a State must allow all four headlighting systems and cannot require only one of them.; If Maine officials would like the NHTSA to consider changing thes existing Federal requirements for motor-driven cycles, they should submit a petition for rulemaking pursuant to 49 CFR Part 552 for an amendment to Standard No. 108.; If you have any further questions I would be pleased to answer them. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3734OpenMr. M. Iwase, Manager, Technical Administration Department, Koito Manufacturing Co., Ltd., Shizuoka Works, 500, Kitawaki, Shimuzu-shi, Shizuoka-ken, 424, Japan; Mr. M. Iwase Manager Technical Administration Department Koito Manufacturing Co. Ltd. Shizuoka Works 500 Kitawaki Shimuzu-shi Shizuoka-ken 424 Japan; Dear Mr. Iwase: This is in reply to your letter of June 22, 1983, to Mr. Medlin of thi agency asking for an interpretation of the recent amendment to Motor Vehicle Safety Standard No. 108 allowing use of replaceable bulb headlamp systems.; Regarding plastic lens materials, you have asked the limits o luminance transmittance loss and presence of haze after outdoor exposure test. These values are those specified by the referenced SAE standard, J576c.; You have also asked whether an accelerated weathering test i acceptable, such as ASTM E 838. Our reply is that you are free to conduct any accelerated weathering test you deem appropriate to support certification of compliance to Standard No. 108. We have not adopted any such test and will perform our compliance tests according to the 3-year test in SAE J576c.; Regarding the structural configuration of headlamps, you have aske about methods that may be acceptable to joining the lens and reflector, such as glue or welding. Standard No. 108 specifies no method for joining components, and any method is acceptable which results in an indivisible lens-reflector unit. Use of clips to supplement glue is permissible but use of clips alone would not result in an indivisible lens-reflector assembly. There is no objection to use of an additional rubber boot behind the reflector and bulb in the manner depicted in your letter. Drain holes, etc. may be provided as long as the headlamp complies with all the requirements of Standard No. 108. We shall publish in the near future a clearer indication of the headlamp terminal arrangement, as well as the dimensional specifications of the connector to the terminals of the bulb socket. We do not understand your request about the specific dimension and shape of each terminal 'blade' as the length, thickness, and width are already specified in the amendment (Figure 3-3). You have asked also whether the wattage values of 65 for the upper beam and 45 for the lower beam are maximum or nominal values. These values are maximum values.; Finally, concerning patent matters, you have asked whether certai aspects of the bulb and socket assembly are the subjects of patent claims. Ford has indicated in a letter of March 2, 1983, that, 'To facilitate compliance with the standard by all who wish to make or use replaceable bulb headlamps or their components, Ford Motor Company offers to grant royalty-free non-exclusive licenses to all manufacturers of motor vehicles, headlamps, or headlamp components that request such licenses, under U.S. patents and U.S. patent applications which claim these inventions to the extent that their use is needed to employ the proposed optional headlamp system.' If you have further questions on this issue you should write to Ford Motor Company.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.