ID: 77-4.21

TYPE: INTERPRETATION-NHTSA

DATE: 10/18/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Lucas Industries North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of August 19, 1977, we advise you that your mistake in referencing S4.5.2 of Standard No. 108 instead of S4.5.1 in your earlier letter of May 13, 1977, does not alter our previous interpretation of June 16, 1977.

Your design appears to meet the specifications of J564a allowing compliance of the headlamp beam switching system with S4.5.1 when installed in a motor vehicle.

YOURS TRULY,

AUGUST 19, 1977

Ref NOA-30

Joseph J Levin, Jr Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration

Subject Lucas 21SA Headlamp Switch Circuit

We thank you for your opinion on the subject switch circuitry that we requested in our letter dated May 13, 1977.

Inadvertently, we had referred to section S4.5.2 of Federal Motor Vehicle Safety Standards 108 when requesting your help, instead of section S4.5.1 of standard 108.

Section S4.5.1 referes to the SAE recommended practice J564a "Headlamp Beam Switching" and it is part 4 of this standard which we are primarily concerned with, that is, "the switch shall be designed so that the headlight circuits are never maintained open" (The absence of a dead spot).

We again submit the wiring circuitry for the subject headlamp switch and ask that you re-evaluate this circuit as per section S4.5.1 and forward your opinion to us.

Eric E Gough Staff Assistant (Technical)

cc: K. J. JONES 21SA HEADLAMP BEAM SWITCH CIRCUIT

[Graphic omitted) (Illegible Text) (Illegible Text)

JUN 16 1977

Eric E. Gough Staff Assistant (Technical) Lucas Industries North America, Inc.

DEAR MR. GOUGH:

This is in reply to your letter of May 13, 1977, to the Administrator asking whether the circuitry diagram that you enclosed would allow compliance with S4.5.2 of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S4.5.2 requires that "each vehicle shall have a means for indicating to the driver when the upper beams of the headlamps are on that conforms to SAE Recommended Practice J564a, April 1964 . . . ." Your diagram appears to meet the specifications of J564a allowing compliance of the system with S4.5.2 when installed in a motor vehicle. The entity legally responsible for compliance with S4.5.2, of course, is the vehicle manufacturer who must certify that its products meet all applicable Federal motor vehicle safety standards.

YOURS TRULY,

Joseph J. Levin, Jr. Chief Counsel

cc: MR. VINSON; MR. CARTER

MAY 13, 1977 The Administrator National Highway Traffic Safety Administration

Our sister company in Birmingham England, Lucas Electrical Limited, requests clarification of Section 4.5.2 of Standard 108 - Lamps, Reflective Devices and Associated Equipment - and SAE Recommended Practice J564, which is referenced in Standard 108, Section 4.5.2.

We submit a diagram of a four headlamp installation in which a Lucas Model 21SA switch and a normally closed relay is used to ensure that the headlight circuits cannot be held in the open condition. Manual and auto reset switches are also included in the circuit to ensure correct circuit operation. We are also submitting traces showing the transient voltage conditions when switching from:

a) Main beam to dip beam

b) Dip beam to main beam

This circuitry we have developed allows, as far as we are aware, for us to comply with Section 4.5.2 of Standard 108. We look forward to receiving whatever comments you deem applicable and will be pleased to supply additional material if you so desire.

LUCAS INDUSTRIES NORTH AMERICA INC

Eric E Gough Staff Assistant (Technical)

ENC

21SA HEADLAMP BEAM SWITCH CIRCUIT

[Graphics omitted)

b) LUCAS 21SA SHY DIP BEAM --> MAIN BEAM

(Graphics omitted) (Illegible Text)

ID: 22894.ztv

Mr. Tadashi Suzuki
Manager, Regulation & Homologation
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan





Dear Mr. Suzuki:

This is in reply to your letter of March 12, 2001, asking for an interpretation of S7.8.5 of Federal Motor Vehicle Safety Standard No. 108.

S7.8.5 specifies that "When activated in a steady-burning state, headlamps shall not have any styling ornament or other feature, such as a translucent cover or grill, in front of the lens." This prohibition was developed when the only headlamps available were sealed beam units. You state that the majority of headlamps today are individually designed for specific vehicles and you believe that the performance of these headlamps can be controlled so that if they have additional parts, the headlamp designer has complete control over them. Therefore "banning of styling parts for all kinds of headlamps has no meaning to safety." For this reason, you "believe S7.8.5 is not applicable to headlamps designed for specific vehicle models."

We do not agree with your interpretation. S7.8.5 contains no qualifying language; it applies to all headlamps. However, S7.8.5 does not prohibit use of a "styling ornament or other feature" in the lens itself, or behind the lens, if the headlamp with these features is certified as complying with Standard No. 108.

We also call your attention to S5.1.3 which, in effect, prohibits additional motor vehicle equipment that impairs the effectiveness of lighting equipment required by Standard No. 108. Any styling feature or other part of a motor vehicle that is in front of the lens of a headlamp in use has the potential to impair the light output of the lamp. Even if there is no impairment initially, grills and covers prevent the lamps from being cleaned. Covers themselves are susceptible to accumulations of dirt and moisture on their inner surface. These accumulations on the outer surface of the headlamp lens can cause glare and reduction in roadway illumination

(S5.1.3 would also prohibit, as original equipment, covers over required lighting equipment other than headlamps, for the same reason of impairment). While our laws do not prohibit the sale of lamp covers in the aftermarket, their installation would create a noncompliance with Standard No. 108. In that instance, there would be a violation of 49 U.S.C. 30122(b) if the covers were installed by a manufacturer, dealer, distributor, or motor vehicle repair business.

Sincerely,

John Womack
Acting Chief Counsel

ref:108
d.5/9/01

ID: nht87-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/08/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: John B. Walsh -- Corporate Attorney, Manager, Legal Affairs Dept., U.S. Suzuki Motor Corp.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 11/21/84 letter from Frank Berndt to U.S. Suzuki Motor Corp. (Std. 108)

TEXT:

John B. Walsh, Esq. Corporate Attorney Manager, Legal Affairs Dept. U.S. Suzuki Motor Corp. P.O. Box 1100 Brea, CA 92621

This is in reply to your letter of August 15, 1986, to Mr. Vinson of this office, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

You cite Table IV's requirement that the minimum edge to edge distance from a motorcycle's front turn signal to the headlamp be a minimum of inches. Referring to a similar requirement for rear lamp spacing and previous agency interpretations stating that this applies only when there are single rear lamps mounted on the vertical centerline, but not when dual stop and tail lamps are mounted on either side of the centerline, you have asked for an interpretation that an exception from the minimum turn signa l spacing requirement is also permissible when a motorcycle has two headlamps rather than one.

We are unable to provide the requested interpretation because of SAE J588e, September 1970. SAE J588e is incorporated by Standard No. 108 and applies to turn signal lamps in use on passenger cars, motorcycles, and all other motor vehicles. Paragraph 4.2 of SAE J588e establishes the requirement that "the optical axis (filament center) of the front turn signal shall be at least 4 in. from the inside diameter of the retaining ring of the headlamp unit providing the lower beam." This requirement applies reg ardless of the number or location of motor vehicle headlamps. SAE J588e did not prevent the issuance of the earlier interpretations regarding rear lamp spacing since that SAE standard does not establish requirements for minimum separation between turn si gnals and rear lamps.

I hope that this answers your question.

Sincerely, Erika Z. Jones Chief Council

15 August 1986

Mr. Taylor Vinson Room 5219 Office of Chief Counsel. NOA-30 National Highway Traffic Safety Administration 700 Seventh Street. SW Washington, DC 20590

Dear Mr. Vinson:

Subject: Request for Interpretation - FMVSS 108

On November 21, 1984, the Chief Counsel confirmed a 1972 agency interpretation of FMVSS 108, Lamps, Reflective Devices, and Associated Equipment (copy of 1972 interpretation, 1984 request, and your office's 1984 response enclosed). The 1972 interpretatio n was for a motorcycle rear lighting configuration. This letter is to request confirmation that the July 1972 interpretation of FMVSS 108 could apply to a motorcycle front lighting configuration as well as the addressed rear lighting configuration.

Table IV of FMVSS 108 required that motorcycle front turn signals be separated by 16 inches or more (centerline to centerline). and that minimum edge to edge distance from the turn signal to the headlamp be 4 inches or more.

We are exploring the possibility of using a front lighting configuration essentially comparable to current practice in passenger car front lighting configurations. This proposed front lighting configuration would consist of a single lamp unit located nea r the outer edge of each side of the front of the motorcycle. The inboard part of the lamp unit would be the headlamp and the outboard part of the lamp unit would be an amber turn signal lamp. Turn signal lamp separation would be equal to or greater than the 16 inch minimum required (see sketch attached).

We would like you to confirm, as in the 1972 and 1984 interpretations, that the minimum edge to edge separation distance of 4 inches between turn signals and headlamp applies when single headlamps are installed on the vertical centerline, but not when du el headlamps are installed on either side of the centerline.

Thank you for your consideration of this request.

Sincerely,

U.S. SUZUKI MOTOR CORP.

(See 11/21/84 correspondence between Frank Berndt and Suzuki)

ID: aiam2850

Dear Mr. Young: This is in belated reply to your letter of December 15, 1977 requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. Your request concerned the legality of installation on motor vehicles of remote manual or of automatic headlamp aiming equipment.; If a headlamp assembly meets the requirements of Standard No. 108 whe installed with or without auxiliary means of aiming, we consider the assembly to be in conformance. Your device does not appear to impair the effectiveness of the required lighting equipment within the prohibition of S4.1.3, and either device that you described would apparently provide an additional safeguard against glare when the rear of the vehicle is heavily loaded.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: 19089.ztv

Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636, Japan

Re: Headlamp Lens Coating

Dear Mr. Suzuki:

This is in reply to your letter of November 5, 1998, asking for an interpretation of S5.1.2 of Federal Motor Vehicle Safety Standard No. 108.

According to your letter, Stanley Electric Co. has developed a new coating to "be applied to the inner surface of the headlamp lens for the purpose of" preventing frost. You relate that "the lens with its original coating applied to the outer surface" complies with Standard No. 108 after the 3-year outdoor exposure test of S5.1.2(b). The application of the inner coating "will not cause any change in the conformity of the original lens with its outer surface coating." For this reason, you believe that no further testing is required after application of the inner coating, and you ask whether your interpretation is correct.

Standard No. 108 does not require headlamp lenses to be coated on either the outer or inner surface. However, some manufacturers of headlamps with plastic lenses coat the outer surface of the lens as a means of ensuring that the plastic materials used in the lens meets the requirements of SAE Recommended Practice J576 JUL91, incorporated by reference in S5.1.2, and the requirements of S7.4(h) of Standard No. 108.

We cannot answer your question. Stanley must ensure that its headlamps as manufactured conform with all requirements of Standard No. 108. It is Stanley's responsibility in certifying compliance of the headlamp with all applicable standards within

Standard No. 108 to determine whether a coating on the inner surface of the plastic lens would result in a noncompliance of the plastic materials with S5.1.2 after a 3-year exposure test, whether or not Stanley conducts an actual test. Further, Stanley must ensure that the presence of the inner coating does not affect the ability of the headlamp to meet all the requirements that apply to it.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.12/22/98

ID: 2343y

Herr Tilman Spingler
Robert Bosch GmbH
Postfach 42
7410 Reutlingen
W. Germany

Dear Herr Spingler:

This is in reply to your FAX to Richard Van Iderstine of this agency, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

Your first question is:

1) To turn the adjusting screws of a HB-2 headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?

Section S7.7.2 requires a headlamp to be installed with a mounting and aiming mechanism that allows aim inspection and adjustment, "and is accessible for those uses without removal of any vehicle parts, except for protective covers removable without the use of tools." The section is not directed to the number of covers, only the ease of removal for the specified purposes. Therefore, the use of two snap on covers is not prohibited by Standard No. 108.

Your second question is:

2) A combination of HB2-headlight (low + high beam) and auxiliary driving beam in one unit shall be equipped with only vertical adjusting screws for the driving beam. The beam pattern will be so wide that even bulbs with extreme tolerances will allow to meet all photometric requirements without horizontal adjustment. Will this be legal?

Under section S7.7.2, the aiming mechanism of a headlamp must allow for adjustment of both horizontal and vertical aim. Thus, the portion of the lamp that provides the lower and upper beam must have both horizontal and vertical aiming screws, and the headlamp would not comply with S7.7.2 if either aiming screw is lacking. For that part of the same headlamp that is a driving beam and which is therefore not regulated by Standard No. l08, the manufacturer may provide any means of adjustment it wishes, as long as it does not impair the effectiveness of the aim of the upper and lower headlamp beam. Your final question is:

3) When will the 9007 bulb be legal? Date of final rule?

According to the plans of this agency, further action on the 9007 (proposed to be known as HB5) is expected in May l990.

I hope that this responds to your questions.

Sincerely,

Stephen P. Wood Acting Chief Counsel

/ref 108 d:3/23/90

ID: aiam3803

Dear Mr. Davis: This is in reply to your letter of December 29, 1983, with respect t the 'Headlight Kit' which you manufacture as 'an aftermarket add-on headlamp concealment device for the Camaro.' You have stated that it will be sold in retail outlets and be offered by Chevrolet dealers as a new car option. You have asked whether the product requires certification under Safety Standard No. 112, and, if so, how may it be included in your packaging and promotional material. If you are not required to certify, you would like to know if you may use the DOT symbol and the phrase 'meets Federal safety standards' on your packaging.; We have two types of safety standards: those that vehicles must meet and those that individual equipment items must meet. Safety Standard No. 112, *Headlamp Concealment Devices*, is an example of the former, when equipped with a headlamp concealment device, a vehicle must meet certain performance requirements. The vehicle must meet these requirements at the time of sale to the first purchaser for purposes other than resale, and be certified as meeting the requirements. Certification of compliance with the vehicle safety standards is provided by the vehicle manufacturer, however, if the vehicles is altered before its sale, in more than a minor way, the alterer must provide an additional certification identifying himself as a modifier and that the vehicle as modified continues to meet the standards. Assuming that Chevrolet dealers perform the modification, it is they, not you, who must apply the alterer's label. The alterer's certification requirements are contained in 49 CFR Section 567.7.; Once a vehicle has been sold, no alterer's certification is required but the party performing the alterations is required to insure that he is not 'rendering inoperative in whole or in part' the headlighting system. We would interpret this to mean that if the concealment system's performance were not the equivalent of that obtainable under Standard No. 112 a violation might exist. The prohibition is established by Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. However, the prohibition does not preclude the vehicle owner from himself making any modification he chooses (subject, of course, to local law).; This means that regardless of whether your system is sold to new ca dealers or to retail stores in the aftermarket your company has no certification responsibility. Thus, the use of a DOT symbol would be improper and could even be viewed as technically false and misleading under Section 108(a)(1)(C) of the Act, for which a civil penalty might be imposed. The phrase 'meets Federal safety standards' is also inaccurate. However, if your tests and other date clearly indicate that a Camaro would meet Standard No. 112 with the system in place, we would not object to your including a qualifying phrase such as 'Vehicle can meet Federal Motor Vehicle Safety Standard No. 112 if system is installed in accordance with instructions.' That would afford a basis upon which the new car dealer could rely in affixing his alterer's label, and would reassure an after-sale modifier that he was not violating the Act.; I hope that this has been helpful to you. For your information, enclose copies of Standard No. 112, 49 CFR Part 567, *Certification*, and the Act.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3802

Dear Mr. Davis: This is in reply to your letter of December 29, 1983, with respect t the 'Headlight Kit' which you manufacture as ' an aftermarket add-on headlamp concealment device for the Camaro.' You have stated that it will be sold in retail outlets and be offered by Chevrolet dealers as a new car option. You have asked whether the product requires certification under Safety Standard No. 112 and, if so how may it be included in your packaging and promotional material. If you are not required to certify, you would like to know if you may use the DOT symbol and the phrase 'meets Federal safety standards' on your packaging.; We have two types of safety standards: those that vehicles must meet and those that individual equipment items must meet. Safety Standard No. 112, *Headlamp Concealment Devices*, is an example of the former, when equipped with a headlamp concealment device, a vehicle must meet certain performance requirements. The vehicle must meet these requirements at the time of sale to the first purchaser for purposes other than resale, and be certified as meeting the requirements. Certification of compliance with the vehicle safety standards is provided by the vehicle manufacturer, however, if the vehicle is altered before its sale, in more than a minor way, the alterer must provide an additional certification identifying himself as a modifier and that the vehicle as modified continues to meet the standards. Assuming that Chevrolet dealers perform the modification, it is they, not you who must apply the alterer's label. The alterer's certification requirements are contained in 49 CFR Section 567.7.; Once a vehicle has been sold, no alterer's certification is required but the party performing the alterations is required to insure that he is not rendering inoperative in whole or in part' the headlight system. We would interpret this to mean that if the concealment system's performance were not the equivalent of that obtainable under Standard No. 112 a violation might exist. This prohibition is established by Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. However, the prohibition does not preclude the vehicle owner from himself making any modification he chooses (subject, of course, to local law).; This means that regardless of whether your system is sold to new ca dealers or to retail stores in the aftermarket your company has no certification responsibility. Thus, the use of a DOT symbol would be improper and could even be viewed a technically false and misleading under Section 108(a)(1)(C) of the Act, for which a civil penalty might be imposed. The phrase 'meets Federal safety standards' is also inaccurate. However, if your tests and other data clearly indicate that a Camaro would meet Standard No. 112 with the system in place, we would not object to your including a qualifying phrase such as 'Vehicle can meet Federal Motor Vehicle Safety Standard No. 112 if system is installed in accordance with instructions.' That would afford a basis upon which the new car dealer could rely in affixing his alterer's label, and would reassure an after-sale modifier that he was not violating the Act.; I hope that this has been helpful to you. For your information, enclose copies of Standard No. 112, 49 CFR Part 567, *Certification*, and the Act.; Sincerely, Frank Berndt, Chief Counsel

ID: 1985-01.40

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd.

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

This is in reply to your letter of January 11, 1985, to Mr. Vinson of this office, asking for a clarification of certain terminology relating to the definition of a standardized replaceable light source in Motor Vehicle Safety Standard No. 108.

We are aware of the problem underlying your question, i.e., that the standard contemplates testing of the bulb with its base but the photometrics specified are appropriate for the capsule portion alone. Our Rulemaking staff is reviewing this issue. The agency will inform you of the results of that review. If appropriate, the issue will be addressed through an appropriate interpretation or amendment of the standard.

Sincerely,

Frank Berndt Chief Counsel

January 11, 1985

Attn: Mr. Taylor Vinson Lawyer

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

Dear Mr. Vinson,

We are a little bit confused with your wordings in a current FMVSS 108 particularly on S3 "Definition" of specifying "Standardized Replaceable Light Source".

By the S3, Definition of Standardized Replaceable Light Source, it specifies that it is an assembly of a headlamp bulb, base and terminals as described in Fig. 3.

From the above S3 Definition, it can also be interpreted that the means a halogen capsule alone without base as described in Fig. 3 -5.

The lumen values specified in a (b) (1), the general specification of the bulb shall be: for standardized replaceable light source required in S4.1.1.38 of FMVSS 108, can we take that values measured from a halogen capsule alone, without base? Because the wordings are very ambiguous. Please refer the wordings and words underline in the attached.

What is more, at the (b) in S4.1.1.38 says, the bulb portion of the standardized replaceable light source, this bulb portion and the bulb in the (b) (1), the general specification of the bulb shall be: you are talking the same thing, Bulb only (means capsule) without base, we presume.

We would appreciate it very much if you would clarify the each meaning of the word, "Bulb" colored in blue and assembly, light source and the relation between the above words and standardized replaceable light source in the attached.

Sincerely,

Stanley Electric Co., Ltd.

T. Chikada, Manager Automotive Lighting Engineering Control Dept.

Encl. Copies of FMVSS 108 (5) KW/es

Federal Motor Vehicle Safety Standard No.108

Lamps, reflective devices, and associated equipment

S1. Purpose and scope

This standard specifies requirements for original and replacement lamps, reflective devices, and associated equipment necessary for signaling and for the safe operation of motor vehicles during darkness and other conditions of reduced visibility.

S2. Application

This standard applies to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers (except pole trailers and trailer converter dollies), and motorcycles, and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies.

S3. Definitions

"Headlamp test fixture" means a device designed to support a replaceable bulb headlamp in the test position specified in the laboratory tests in S4.1.1.36(d), and whose mounting hardware and components are those necessary to operate the headlamp as installed in a motor vehicle.

"Replaceable bulb headlamp" means a headlamp comprising a bonded lens and reflector assembly, and a standardized replaceable light source.

"Seasoning" means a process of energizing the filament of a headlamp, at design voltage, for a period of time equal to 1 percent of average rated laboratory life.

"Standardized replaceable light source" means an assembly of a headlamp bulb, base, and terminals, as described in Figure 3.

S4. Requirements S4.1 Required motor vehicle lighting equipment

S4.1.1.38 Each standardized replaceable light source shall conform to the following requirements: (a) A silicone O-ring shall be provided. (b) The bulb portion of the standardized replaceable light source shall meet the requirements in paragraphs (b)(1) through (b)(6) of this section.

(1) The general specifications of the bulb shall be:

Low beam High beam Maximum power, watts at 2.8V (design voltage) 50 70

Lumens (without black cap) at 12.8 V design voltage 1.067 + 10% 1.738 + 10%

Average life at 14.0 V rated voltage (life testing 320 hrs 150 hrs as conducted in a finished headlamp assembly placed in the normal operating attitude)

(2) The bulb filaments shall be subject to seasoning prior to wattage and lumens measurement. (3) Wattage and lumens measurements shall be made with the direct current test voltage regulated within one quarter of one percent. (4) Except for reference dimensions, and unless otherwise specified, a general tolerance of +0.004 in. (0.10 mm) shall apply to all linear dimensions and +1o.00' shall apply to all angular dimensions. (5) Bulb, lead wires and/or terminals shall be installed in the base so as to provide an airtight seal. (6) After a bulb deflection test conducted in accordance with S7, the permanent deflection of the glass envelope of each standardized replaceable light source shall not exceed 0.005 inch (0.13 mm) in the direction of the

ID: nht91-4.3

DATE: May 22, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: George D. Powley -- Project Engineer, Truck-Lite Co., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 4-29-91 from George D. Powley to Paul Jackson Rice (OCC 6011)

TEXT:

This responds to your letter of April 29, 1991, with respect to the orientation of electrical contact blades on sealed beam headlamps.

Truck-Lite would like to produce both a large rectangular Type 2B1 sealed beam headlamp and a small rectangular Type 2A1 headlamp using the same blade orientation. Specifically, you would like to use the 2B1 orientation on the 2A1 unit. You do not feel that this would affect adversely the lamp's "ability to interchange with existing lamps in motor vehicles presently in the field."

The basic dimensional requirements for sealed beam headlamps are set forth in SAE Standard J1383 APR85 Performance Requirements for Sealed Beam Headlamps, incorporated by reference in Motor Vehicle Safety Standard No. 108. However, in reference to the Figures of J1383 which set forth the dimensions, "only those dimensions marked 'I' for interchangeability are applicable." (Section S7.3 of Standard No. 108). Our examination of the Figures indicate that the electrical contact blade orientation dimensions for Type 2A headlamps are marked "I", and thus must be met by Type 2A headlamps designed to comply with Standard No. 108. On the other hand, the contact blade orientation dimensions for Type 2B headlamps do not appear to be marked "I", and the manufacturer may depart from the ones indicated without violating Standard No. 108.

This means that you could not use a Type 2B1 blade orientation on a Type 2A1 headlamp as you wish. On the other hand, you could use the Type 2A orientation on the Type 2B, if you find it feasible to do so.

You also indicated that Koito is currently selling Type 2A1 headlamp with a non-standard contact blade orientation. I have forward a copy of this letter to our Office of Vehicle Safety Compliance for appropriate action. Thank you for calling this matter to our attention.