ID: 20837.ztv

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

Re: Headlamp Optical Axis Marking

Dear Mr. Suzuki:

This is in reply to your letter of October 15, 1999, asking whether the marking intended to designate the optical axis on a new headlamp complies with S7.8.1(b) of Federal Motor Vehicle Safety Standard No. 108. This section requires the optical axis of visually/optically aimable headlamps to be designated by a mark.

The headlamp assembly will be used on cars intended both for Japan/Europe and the United States and has a common lens, though the light sources will differ. The headlamp intended for Japan/Europe will contain two light sources, each with its own reflector, whereas the U.S. version will be equipped with a single HB5 bulb and a single reflector. The optical axes will be marked on the lens, the U.S. version with a single circle, and the other version with two small diamonds. You relate that the lens is a clear one so that the light sources can be seen easily from outside the lens, and do not believe that multiple markings will create confusion.

The lens is properly marked as required by S7.8.1(b). The two non-required optical axis markings are permissible so long as they do not cause confusion with respect to the required marking. You indicate that the HB5 light source can be clearly seen behind the transparent lens. Therefore, we agree with you that there should be no confusion about the location of the optical axis of the U.S. version headlamp when it is necessary to assure proper horizontal and vertical alignment of the aiming screen or optical aiming equipment.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.3/27/00

ID: nht88-1.96

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 14, 1988

FROM: C. DIANNE BLACK -- ENGINEERING MANAGER, JAGUAR

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: FMVSS 108, HEADLAMP LEVELLING SYSTEMS

ATTACHMT: MEMO DATED 8-1-88, TO C. DIANNE BLACK, FROM ERIKA Z. JONES, STD 108

TEXT: Thank you for your letter of February 1, 1988 which discussed our June and October 1987 letters regarding a headlamp levelling system for our US models.

We have reviewed your letter, and we have decided that we should go one step further and provide a drawing of the switch, showing its location on the steering column shroud and to perhaps better describe its operation.

To reiterate from our October 17, 1987 letter, the switch has three positions -

zero = driver only or

driver plus front passenger or

driver plus front and rear passengers

one = driver plus passengers plus maximum trunk load

two = driver plus maximum load in trunk

The switch/lamp motor system is limited to the above three positions and intermediate settings are not possible. The switch is not a rheostat but rather a 'master/slave' unit. The switch is illuminated by turning on the headlamps and it cannot be turne d off.

Headlamp alignment is adjustable only in the zero position.

We believe that full description in the owner handbook, and the fully visible illuminated switch will enhance owner familiarity with the system and the system can be used to enhance headlighting performance.

We hope this will further clarify the system and allay your concerns over our headlamp levelling system and its operation.

Feel free to contact me should you have further questions.

Headlamp Dipped-Beam Levelling Control

Driver's-Eye View (On Left Steering Column Shroud)

ID: nht81-2.33

DATE: 06/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagon of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 27, 1981, asking for an interpretation of Motor Vehicle Safety Standard No. 108. Your company is considering, for fuel economy purposes, use of an engine stop/start system by which the engine would be switched off within a few seconds after a vehicle has come to a complete stop, and, to save battery capacity, the headlamps would also be deactivated. The parking lamps, however, will remain on. You believe that Standard No. 108 would not preclude such a system.

Although your letter does not mention it, we assume that when the parking lights are activated, the taillamps, license plate lamps, and side marker lamps would also be on, as required by S4.5.7(a) of Standard No. 108. The question then arises whether the system described is prohibited by paragraph S4.1.3 which states that "No . . . motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required" by Standard No. 108. Although the primary function of headlamps is to illuminate the roadway in front of the driver at night or under conditions of reduced visibility, they also serve to indicate the presence of the vehicle to traffic approaching from the opposite direction. In a situation where, on a two-lane road, a car has pulled to the shoulder temporarily, a headlamp will be perceived at a greater distance than a parking lamp to oncoming traffic. Headlamps also serve an illuminating function when people have paused in unfamiliar neighborhoods in an effort to discern their whereabouts. We believe, therefore, that your device could be viewed as impairing the effectiveness of headlamps within the meaning of S4.1.3.

This, however, is not a view dispositive of the issue. Compliance with Standard No. 102 would also appear to be affected as that standard requires that the engine starter be inoperable when the transmission shift lever is in the forward or reverse position. Last year the agency granted a rulemaking petition with respect to an engine stop/start system such as you have discussed. I enclose a copy for your information. Although no notice has yet been published on this question, we shall endeavor to include a reference to headlamp switching devices in any future rulemaking activity on this subject.

ENC.

MAY 27, 1981

Frank Berndt Chief Counsel National Highway Traffic Safety Administration

SUBJECT: Request for Interpretation - FMVSS 108

In order to further improve fuel economy, Volkswagen is investigating the possibility of using an engine stop/start system. This system would automatically switch the engine off within a few seconds after the vehicle has come to a complete stop. When the accelerator is depressed the engine will start again automatically (or, on vehicles with manual transmission, it will start when the gear shift lever is put into first gear). We estimate a fuel savings of 6 to 10 percent, a significant reduction in exhaust emissions and noise pollution with the stop/start system in city driving conditions.

In order not to excessively burden the battery capacity, the stop/start system will have to use a switch mechanism which turns the headlamps off together with the engine. The parking lights will remain on. Once the engine is restarted, the headlamps will be switched on automatically.

When reviewing FMVSS 103, Volkswagen concluded that the standard would not preclude an automatic headlamp switching system as described above. We request your interpretation as to whether Volkswagen's conclusion concerning automatic headlamp switching systems is correct. Your early response to this will be greatly appreciated.

Dietmar K. Haenchen Executive Engineer Vehicle Regulations

ID: 1984-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 05/21/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Hella North America Inc. -- Walter A. Genthe

TITLE: FMVSS INTERPRETATION

TEXT:

January 23, 1984

Dear Mr. Berndt:

Westfaelische Metall Industrie KG is currently designing headlamps for several automobile manufacturers.

These headlamps are designed to comply with Safety Standards 108 as amended by Docket 81-11 (latest issue: Notice 7).

Preliminary requests by our customers mandate an inclusion of parking/front position lamps and/or turn signal lamps and/or side marker lamps in the overall headlamp design.

A standard U.S. light bulb, meeting FMVSS 108 and/or applicable SAE recommended practices, will be used for these respective functions.

We intend to incorporate these functions into the headlamp compartment, retaining the bulb in question by means of a sealed attachment, similar to the one used in the C6 capsule installation.

No degradation of the system will result, since both functions are contained in one sealed compartment, covered by one common lens. No impairment of the effectiveness of the headlamp function is anticipated, nor will the headlamp impair the function of the parking/position/side marker lamp.

All photometric and environmental specifications for such lamps will be met and no component will be used which is outside the scope of FMVSS 108.

To clarify our intent, a sketch showing the principal design has been enclosed.

We are requesting a statement concerning the agency's opinion in this matter; specifically, as it concerns the legality of the proposed system, whole or in part, and solicit any suggestions as to necessary changes should the system not be in compliance with FMVSS 108, as amended by Docket 81-11.

This matter is of considerable urgency, because of design and manufacturing lead times.

A reply at yyor early convenience coud therefore be appreciated.

Very truly yours,

HELLA NORTH AMERICA INC.

Walter A. Genthe President

WAG/1h

Encls.

cc: Dr. Ernst, K 1 Mr. Westermann, K 1 Mr. Fikus, AF

Insert artwork here.

MAY 21, 1984

Mr. Walter A. Genthe President Hello North America, Inc. P.O. Box 499 Flora, Illinois 62839

Dear Mr. Genthe:

This is in reply to your letter of January 23, 1984, with respect to the inclusion of other lighting functions in a replaceable bulb headlamp compartment. These functions could include parking lamps, turn signal lamps, or side marker lamps. The bulb used would meet Standard No. 108/SAE specifications for the function chosen and they would be incorporated into the compartment bya a "sealed attachment." You represent that there will be no impairment of any function, and that the overall assembly will meet all photometric and environmental specifications. You have asked whether such a combination assembly is permissible under Standard No. 108.

The agency interprets Standard No. 108's specifications for replaceable bulb headlamps as allowing only one bulb in a lamp assembly to be used for headlighting purposes. It is silent as to whether additional bulbs may be used to provide other lighting functions. This means that such a bulb is permitted.

Obviously the inclusion of a second bulb can affect the characteristics of the assembly, whether through heat build up, the introduction of contaminants through the junction of the bulb and assembly, etc. These problems would appear to be minimized under the assumptions set forth in your letter. We believe therefore that, under these conditions, an auxiliary bulb could be included in the headlighting compartment, provided that the assembly meets all applicable requirements of Standard No. 108 for each function. Problems that may develop in service would be subject to the safety related defects authority of the National Traffic and Motor Vehicle Safety Act.

If Hella proceeds with a multi-bulb, design, we would like to request that it share with us the types of tests it will be developing which it deems necessary to insure adequate safety performance, so that our knowledge of state of the art lamp technology may be broadened.

Sincerely,

Frank Berndt Chief Counsel

C6/C6 **INSERT GRAPH**

**INSERT GRAPH**

ID: 17933.ztv

Mr. Jim Young
Supervisor
Electrical Engineering
Wheeled Coach
2737 North Forsyth Road
Winter Park, FL 32792

Dear Mr. Young:

This is in reply to your FAX of May 7, 1998, asking for interpretations of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Wheeled Coach is an ambulance manufacturer whose customer specifications may or may not be permitted by Standard No. 108.

Your "Case #1" concerns a customer request for "optically combining high intensity strobe warning lights with the front turn signals." These lamps are not synchronized with the turn signals, nor are they canceled when the turn signals operate. You also relate that the strobe lights are of greater intensity than that of the turn signals.

In your opinion, "it could be argued that the strobes could impair the effectiveness of the turn signals, thereby violating S5.1.3." We agree with your opinion. If the strobe lights are optically combined with the front turn signal lamps, are of higher intensity than those lamps, and are not canceled when the turn signals operate, impairment of the effectiveness of the front turn signals seems likely to occur. However, were the system designed so that the strobe lamps are canceled when the turn signals operate, then there would be no impairment or violation of S5.1.3.

You also mention that the turn signal employs a reflector and a lens to meet photometric requirements and that the reflector would have to have a hole drilled in it to accommodate the strobe tube. There is the possibility that the modification could affect compliance of the front turn signal lamp with applicable requirements. In addition to testing the headlamp with the modified reflector for continued compliance with headlamp photometric requirements, Wheeled Coach should also ensure that the modified headlamp continues to conform with other requirements demonstrating the integrity of the lens/reflector/bulb unit of replaceable bulb headlamps, most importantly the sealing, corrosion, dust, and humidity test requirements.

As the manufacturer of the ambulance, Wheeled Coach has the responsibility of certifying compliance of the vehicle to all applicable Federal motor vehicle safety standards.

Your "Case #2" concerns a customer request for "optically combining high intensity strobe warning lights with the headlights." The headlamps are replaceable bulb types and the reflector in this option also would require modification to accommodate the strobe tube.

You do not mention the operating characteristics of this system. In our opinion, in order not to impair the effectiveness of the headlamp system, the strobe lamps must be canceled at any time the headlamps are activated. If the headlamps on the original vehicle are wired to act as daytime running lamps (DRLs), it is permissible to disconnect them because DRLs are not a required item of lighting equipment. As indicated in the discussion under Case #1, it would be prudent for Wheeled Coach to test the modified headlamps for compliance for photometric and other requirements.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/23/98

ID: nht88-3.47

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 12, 1988

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: M. IWASE -- MGR., TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 10-18-89 TO ERIKA Z. JONES FROM M. IWASE AND LETTER DATED 4-8-88 TO ERIKA Z. JONES FROM M. IWASE. TEXT:

This is in reply to your letter of April 8, 1988, with respect to the agency's proposed S7.7.5.2 of Standard No. 108, on-vehicle aiming requirements which would include a Vehicle Headlamp Aiming Device (VHAD). This was proposed on December 29, 1987, as Notice 5 to Docket 85-15.

You have asked whether two designs contemplated by Koito comply with the VHAD as proposed. With respect to the second design, "Structure-2", you requested that it be considered confidential as it involves a Koito idea related to a patent application. However, you withdrew that request on June 9, 1988.

With respect to your two designs, you appear to have understood that the agency's intent in the proposal was to provide broad parameters for VHADs to afford manufacturers design freedom in meeting the specifications. Under S7.7.5.2 it is the headlamp system that "includes" a VHAD, rather than "incorporates' it. Under subsection (b)(7) photometric testing is provided for "The VHAD and headlamp assembly (if the headlamp is separable or intended to be used with the VHAD)...." This means that the VHAD may be integral with the headlamp assembly, or separate from it (though presumably provided with the vehicle as part of its original equipment), as fits the manufacturer's design. Each of your designs complies with the intent of S7.7.5.2; however, I must emphasize that this is only a proposal, and the form of a final requirement, if any, has not been determined.

We have further comments about your devices. Structure 1 incorporates a stationary lens and housing, but the reflector is adjustable. The lamp must be designed to conform to the photometric requirements of Standard No. 108 with the reflector in any position within the proposed aimability range of +/- 4 degrees vertical and +/- 2 1/2 degrees horizontal, or any combination thereof. Structure 2 features a detachable spirit level which is inserted when the replaceable bulb is removed from the headlamp. Although the proposal does not specifically prohibit this feature, the test procedures do not anticipate a VHAD design where the light source would be removed and replaced with the VHAD.

I hope that this answers your question.

ID: 20832.ztv

Mr. Joel Martin
1231 SW 3^rd Ave
Suite 123C Building A
Gainesville, FL 32601

Dear Mr. Martin:

Thank you for your fax of October 19, 1999, asking for information on "how I can apply for a financial exemption for a new manufacturer of 49cc Scooters." You relate that the manufacturer "meets all the CFR requirements," but is concerned that one of the lamp manufacturers does not label his product with a DOT symbol. You report, however, that "the light in testing meets the National Highway Traffic Safety Administration testing standards."

Mr. Vinson of this Office, with whom you spoke, recalls that the lamp in question is the headlamp for motor driven cycles. Paragraph S7.2(a) of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, requires the lens of any headlamp used on a motor vehicle, including motor driven cycles, to be marked with the symbol DOT which shall constitute the certification required by 49 U.S.C. 30115. If the headlamp is not so marked, and if testing of the headlamp shows compliance with the motor driven cycle headlamp specifications of SAE J584 April 1964, that would afford a basis upon which its manufacturer could certify compliance. In that event, a temporary exemption would not be required. Please note that S7.9.5 requires that headlamps meeting SAE J584 must also have the word "motorcycle" permanently marked on the lens.

Our temporary exemption procedures are set forth in 49 CFR Part 555. Because of the statutory requirement that we afford the public an opportunity to comment on petitions for exemptions, the process from receipt of an acceptable petition to action on it requires three to four months. While you may submit it on behalf of the manufacturer, the manufacturer must sign the petition. If the manufacturer is located outside the United States, it must first designate an agent for service of process pursuant to 49 CFR 551.45.

A person who is not a manufacturer of a motor vehicle certified for sale in the United States may import a non-conforming motor vehicle for research or investigations pursuant to 49 CFR 591.5(j)(1) and (2)(i) after receiving written permission from the agency (49 CFR 591.6(f)(1)).

You may access our regulations at in Title 49 Code of Federal Regulations through website

www.nara.gov/fedreg.

If you have any further questions, you may telephone Mr. Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref.567#108
d.12/6/99

ID: nht90-1.42

TYPE: INTERPRETATION-NHTSA

DATE: 02/13/90

FROM: RICH VAN IDERSTINE

TO: TAYLOR

TITLE: INCOMING REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 3-23-90 TO TILMAN SPINGLER, ROBERT BOSCH GMBH, FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; INTERP. STD. 108]; ALSO ATTACHED TO TELEFAX DATED 1/30/90 TO RICHARD VAN IDERSTINE FROM T. SPINGLER.

TEXT: Attached is a fax from Bosch that I received last Friday through some circuitous internal NHTSA mail routing.

To help in your preparation of a letter (fax?) of interpretation, I offer the following:

Question 1. "To turn the adjusting screws of a HB2-headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?"

S7.7.2 permits protective covers removable without the use of tools, for meeting the need for accessibility of mechanisms that allow aim inspection and adjustment for both vertical and horizontal aim.

Question 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 w ill allow to meet all photometer requirements without horizontal adjustment. Will this be legal?"

Again, S7.7.2 states that each headlamp shall be installed with a mounting and aiming mechanism that allows aim inspection and adjustment of both vertical and horizontal aim. . . . Thus, the headlamp in question must have both horizontal and vertical aiming screws for that part of the headlamp which provides the lower and upper beam. For that part of the same headlamp which is a driving beam and thus not regulated by Standard No. 108, NHTSA does not care how that is made adjustable for aiming purpo ses. Therefore the headlamp as described would not be legal if it did not have horizontal aiming screws or the equivalent mechanism for that part which provides the lower and upper beam.

Question 3. "When will the 9007 bulb be legal? Date of final rule?"

The next action on the HB5 (industry trade no. 9007) is expected in May 1990, as was stated in the January 18, 1990 NHTSA-Industry Public Meeting.

Attachment

P.S. Could you have your secretary send a copy of the latest 108 over the WANG System to me?

Thanks, (Illegible Word)

ID: nht88-1.91

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 8, 1988

FROM: M. IWASE -- MANAGER, TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: Headlamp Aimability (Docket No. 85-15; Notice 5)

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 10-18-89 TO ERIKA Z. JONES FROM M. IWASE AND LETTER 9-12-88 TO M. IWASE FROM ERIKA Z. JONES. TEXT:

We would ask you to provide us with your confirmation of interpretation of proposed rulemaking; Headlamp Aimability as cited in Docket No. 85-15; Notice 5 of Federal Register dated Dec. 29, 1987.

We are now in the stage of studying and developing a new technology of on-vehicle aiming (Vehicle Headlamp Aiming Device) in conformity with the said NHTSA proposal so that we can adopt it into our headlamps as soon as possible in case that the proposal is put into effect as a rule.

Upon our careful review to this proposal and also through our talk with Mr. Richard Van Iderstine / Rulemaking Office of NHTSA, our ideas for headlamp aiming configuration as shown in the attached sheet are fully consistent with NHTSA's intention for hea dlamp aimability proposed therein, we believe.

Please refer to the attached sheet in which our specific questions are shown.

We would greatly appreciate it if you would kindly treat Structure-2 of attached as "Confidential" because it involves our own idea for development of on-vehicle aiming which has something related with our patent application intended hereafter.

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

Attachment

Question:

Whether the following structure of on-vehicle aiming could be accepted in case that the proposed requirements of S7.7.5.2 "On-Vehicle aiming" would be regulated in the FMVSS No. 108 as they are.

Structure-2: Built-in Reflector System [GRAPHICS OMITTED]1) Lens and Housing are bonded together.

2) Built-in reflector is mounted with aiming mechanism onto Housing.

3) Aiming is made by adjusting faced direction of built-in reflector.

4) Spirit level is mounted on built-in reflector and can be seen through lens for the vertical aiming.

5) Headlamp assembly can comply with the applicable requirements of FMVSS No. 108.

ID: 24572.ztv

Mr. Robert G. Mills
Supervisor, Homologation and Publications
Triumph Designs Limited
Jacknell Road,
Dodwells Bridge Industrial Estate
Hinckley, Leics. LE10 3BS
England

Dear Mr. Mills:

This is in reply to your letter of June 17, 2002, seeking a further clarification of the applicability of S7.9.6.2 of Federal Motor Vehicle Safety Standard No. 108 to motorcycle headlamp designs that Triumph is contemplating. You have enclosed two illustrations of potential designs. You referred at various points in your letter to "main beam" and "dipped beam." These are not terms used in Standard No. 108. For purposes of this reply, we assume that "main beam" means "upper beam," and that "dipped beam" means "lower beam."

In our letter of May 24, 2002, to you, we pointed out that the Triumph headlamp design discussed in that letter should be designed to comply with S7.9.6.2(a), rather than S7.9.6.2(b) as you had originally thought. Your review of that paragraph has raised doubts as to whether your design meets that paragraph. The sentence of S7.9.6.2(a) that concerns you reads:

If the headlamp contains more than one light source, each light source shall be mounted on the vertical centerline with the upper beam no higher than the lower beam, or horizontally disposed about the vertical centerline and mounted at the same height.

Illustration 1 depicts two upper ("main") beam and two lower ("dipped") beam light sources, horizontally disposed about the vertical centerline, with the lower beam sources mounted below and inboard of the upper beam light sources. You informed us that your design does not permit mounting all four light sources at the same height, but nevertheless ask whether the design is acceptable since the individual beams will be mounted at the same height. Illustration 2 depicts a "headlamp unit containing three light sources," the center light source providing the upper beam and that the two adjacent light sources, mounted slightly higher, providing the lower beam. You ask whether this three-light source design is acceptable.

The headlamp designs shown in Illustration 1 and Illustration 2 do not meet the design requirements of S7.9.6.2(a) because all light sources are not mounted at the same height, though horizontally disposed about the vertical centerline.

You also asked whether incorporating different numbers of light sources for upper and lower beams, as in Illustration 2, would comply with Standard No. 108. There is no restriction for the number of light sources used in the upper or lower beams of a motorcycle headlamp system designed to conform to the photometry requirements of S7.9.2(a) and the installation requirements of S7.9.6.2.

ref:108

d.8/9/02