ID: aiam3149

Dear Mr. Howard: This is in response to your letter of June 19, 1979, and i confirmation of your telephone conversation with Mr. Schwartz of my office.; The VIN format you forwarded with your letter is essentially correct There are, however, several aspects of it which should be modified. They will be discussed as numbered in your letter.; It is important to point out at the outset that Standard 115 require Carolina International Inc. to assign a VIN to only those vehicles for which it is the first stage manufacturer, in this case trailers. Ford and General Motors will be assigning a VIN to those vehicles for which it is the first stage manufacturer, even though Carolina is the final stage manufacturer.; I. World Identification Numbers. The first three characters of the VIN designate the manufacturer, make and type of vehicle. While Carolina is the final stage manufacturer for several types of vehicles, it is the first stage manufacturer for only one type. Consequently, one manufacturer identifer is sufficient. As the Agency has contracted with the Society of Automotive Engineers (SAE) to act as its agent in assigning these identification codes (see enclosed notice), you should communicate with the SAE if your identifier was not assigned by it.; II. Vehicle Description Section (VDS). Your proposed coding for the VDS is satisfactory, except that i encodes data relating to vehicles produced by other manufacturers who would, as explained above, assign the VIN for those vehicles.; III. Check Digit. The mathematical values assigned to the alphabetic characters are no correct. Please consult Table IV in Notice 8 (44 FR 17489, March 22, 1979) which I have enclosed.; IV. Vehicle Indicator Section. The format utilized in this section is correct, except that the serie of trailer must be indicated in the Vehicle Descriptor Section. Perhaps this can be encoded where you previously intended to indicate chassis type (2.4).; I hope this information has been helpful. Please write or call Mr Schwartz of my office at 202-426-1834 should you have any additional questions.; Sincerely. Frank Berndt, Chief Counsel

ID: nht90-3.86

TYPE: Interpretation-NHTSA

DATE: September 7, 1990

FROM: Carol C. Verenes -- District Transportation Supervisor, Aiken County Public Schools

TO: Joseph J. Levin, Jr. -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1-15-91 to Carol C. Verenes from Paul Jackson Rice (A37; Part 571.3)

TEXT:

I am writing to request your assistance in providing our school district with written correspondence relative to the U.S. Department of Transportation, National Highway Traffic Safety Administration, adopted safety standards effective April 1, 1977, whic h applies to vans transporting school children. Additionally, our district is considering modifying several of our existing vans for the purpose of transporting school children to school sponsored events and would like information pertaining to Federal Motor Vehicle Safety Standard No. 220, 221, and 222.

Thank you for your assistance and cooperation regarding our request. Please contact me at (803) 648-1311, ext. 246, if you have any questions.

ID: 2953o

Mr. George Ziolo
DOT Paperwork Processor
234l7 Everett Place
Ramona, CA 92065

Dear Mr. Ziolo:

This is in reply to your letter of April 20, 1988, asking about the acceptability under Safety Standard No. l08 of modifying imported vehicles so that they are equipped with two Type 2D1 and two Type 1C1 headlamps. You have been informed by the agency's Office of Vehicle Safety Compliance that this is impermissible "because they are 'nonconforming' 'headlight systems'." You disagree because you believe that the minimum requirements of the Standard are satisfied by the Type 2D1 lamps, and that "S4.4 appears to permit such a combination."

Paragraph S4.4 is not applicable to the situation you present as it refers to combinations of lamps serving different functions; in your discussion, the lamps serve the identical function of headlighting. Given the fact that the Type 2D1 sealed beam 7" diameter headlamps fulfill the headlighting requirements of the Standard, your question must be viewed as whether a supplement to the headlighting system is permissible under Standard No. l08.

Paragraph S4.l.3 of Standard No. l08 permits the addition of nonrequired lighting equipment provided it does not impair the effectiveness of the equipment that the standard requires. The two Type 1C1 5 3/4" diameter sealed beam lamps in a four lamp headlighting system form the major portion of an upper beam headlighting system. The two Type 2D1 lamps in a two lamp headlighting system form the whole of an upper beam headlighting system. Thus, a vehicle furnished with the systems you posit would be equipped with more than one upper beam headlighting system. The Type 2D1 system must be designed to conform to the photometric requirements of SAE Standard J579c DEC79 "Sealed Beam Headlamp Units for Motor Vehicles." The SAE Standard establishes at two test points, H-V and 4 D-V, maximum allowable candela of 75,000 and 5,000 respectively for each Type 2D1 headlamp. This means that the maximum allowable candela for headlighting systems at these test points is 150,000 and l0,000 candela. The Type 1C1 headlamps will also be designed to conform to SAE J579c. Corresponding maxima at test points H-V and 4 D-V for Type 1C1 systems are 60,000 and 5,000. Thus, a vehicle equipped with the lamps you have described could emit a total of 270,000 candela at test point H-V (when only 150,000 is permitted), and 20,000 at 4D-V (when only l0,000 is allowable).

Agency research has shown that candela readings in excess of 150,000 greatly increase the potential for glare with little increase in seeing ability. This glare would be visible both to the driver of an oncoming car, and the driver of the modified vehicle itself through creation of a "veiling" glare. The addition of the Type 1C1 headlamps would therefore impair the effectiveness of the Type 2D1 headlighting system, and is forbidden by S4.1.3.

We appreciate your interest in safety.

Sincerely,

Erika Z. Jones Chief Counsel

ref:108 d:9/12/88

ID: nht95-2.59

TYPE: INTERPRETATION-NHTSA

DATE: April 28, 1995

FROM: R F Tolley -- Senior Development Engineer, New Products Office, Magneti Marelli UK Ltd. Lighting Division

TO: Chief Council -- Office of Vehicle Safety Standards, NHTSA

ATTACHMT: ATTACHED TO 6/8/95 LETTER FROM JOHN WOMACK TO R. F. TOLLEY (A43; STD. 108)

TEXT: Dear Chief Council

Question concerning FMVSS108

External Aiming - Torque/Deflection Test

I would like to raise a question with you concerning the interpretation of the torque/deflection test contained in FMVSS108 section S7.8.5.1.(a).

I understand that this test is to take into account the weight of beam aiming equipment when aiming lamps. However I believe the instructions for performing the test are not sufficiently precise and can be interpreted in different ways.

Please see attached sketch which I have used to explain my query. In order to determine the downward force which is applied to the lamp, so as to cause the lamp aim to rotate downward, it is necessary to define the centre of rotation of the force. Sinc e torque = downward force multiplied by the distance to the centre of rotation of the force, then

downward force = Torque (20lbf.in) / distance to the centre of rotation of the force

My question is, where is the centre of rotation of the force taken to be? Is it?

a) the centre of the aiming pad pattern,

b) the point at which the axis (which passes through the centre of the aiming pad pattern and is perpendicular to the aiming reference plane), passes through the aiming reference plane,

c) the centroid of the reflector,

d) the centre of rotation of the headlamp assumed to be the centre of the pattern formed by the headlamp adjusters,

e) some other point.

With large, angled modern lamps the difference between the above points can be great, therefore it is important to select the correct point.

In summary my question is- When applying a downward force to create a downward torque (with respect to lamp aim), where is the centre of rotation of the force taken to be?

Attachment: FMVSS 108 EXTERNAL AIMING TORQUE DEFLECTION TEST

(Graphics omitted.)

ID: aiam5487

"Dear Mr. Blous: This responds to your letter asking about how thi agency's regulations might apply to your product. I apologize for the delay in sending this letter. In your letter, you described your product as a bag holder for the interior of vehicles, designed to attach to the head restraint and hang on the back side of the front seats. Based on the illustration you provided, the bag holder appears to be a 12 inch flexible strap that attaches to the head restraint, with a 'rigid plastic' hook at the end from which plastic grocery bags are suspended. The short answer to your question is that, while there are no regulations that apply directly to your product, there are Federal requirements that may affect the sale of this product. I am enclosing a copy of a fact sheet titled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority to issue these regulations is based on title 49, section 30102(7) of the U.S. Code (formerly the National Traffic and Motor Vehicle Safety Act), the relevant part of which defines the term 'motor vehicle equipment' as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component or as any accessory, or addition to a motor vehicle . . . (emphasis added). Although you appear to recognize the applicability of our regulations, based on your characterization of your product as 'after market equipment,' allow me to explain how NHTSA determines whether an item of equipment is considered an accessory under the U.S. Code. The agency applies two criteria. The first criterion is whether a substantial portion of its expected uses are related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an 'accessory' and thus subject to the provisions of the U.S. Code. Your bag holder appears to be an accessory and thus an item of motor vehicle equipment under our regulations. It appears to be designed specifically to fit in motor vehicles using the head restraints, meaning that a substantial portion of its expected use relates to motor vehicle operation. The bag holder would typically be purchased and used by ordinary users of motor vehicles (i.e., anyone using the vehicle). While your bag holder is an item of motor vehicle equipment, NHTSA has not issued any standards for such an item. However, you as a manufacturer of motor vehicle equipment are subject to the requirements in sections 30118-30122 of Title 49 of the U.S. Code concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the product contains a safety related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Although no standards apply directly to the bag holder, there are other provisions of law that may affect the manufacture and sale of your product. NHTSA has issued a safety standard (Standard No. 201, Occupant protection in interior impact) that requires, among other things, that seat backs have a certain amount of cushioning to provide protection when struck by the head of rear seat passengers during a crash. Installation of your product on the back of front seats could have an impact on compliance with that standard. If your bag holder were installed so that a hard object (e.g., the rigid plastic hook) were to be struck by the occupant's head, the requisite amount of cushioning might not be achieved. We do not know how big or how 'rigid' the hook is, but it is something of which you should be aware. Other legal requirements could apply depending on how your product is marketed. If your product were installed by a vehicle manufacturer as original equipment, the vehicle manufacturer would have to certify that the vehicle with the bag holder installed complies with all FMVSS's, including Standard No. 201. In addition, although we recognize it would be unlikely that your product would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, section 30122(b) of title 49 prohibits those commercial businesses from 'knowingly mak ing inoperative any part of a device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard . . .' For instance, compliance with Standard No. 201 might be degraded if the bag holder were mounted in front of rear seat passengers. Any violation of this 'make inoperative' prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. The 'make inoperative' prohibition does not apply to modifications that vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your bag holder in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, NHTSA encourages vehicle owners not to degrade any safety device or system installed in their vehicles. In addition, individual States have the authority to regulate modifications that individual vehicle owners may make to their vehicles, so you might wish to consult State regulations to see whether your device would be permitted. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Mr. Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure";

ID: aiam5486

"Dear Mr. Blous: This responds to your letter asking about how thi agency's regulations might apply to your product. I apologize for the delay in sending this letter. In your letter, you described your product as a bag holder for the interior of vehicles, designed to attach to the head restraint and hang on the back side of the front seats. Based on the illustration you provided, the bag holder appears to be a 12 inch flexible strap that attaches to the head restraint, with a 'rigid plastic' hook at the end from which plastic grocery bags are suspended. The short answer to your question is that, while there are no regulations that apply directly to your product, there are Federal requirements that may affect the sale of this product. I am enclosing a copy of a fact sheet titled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority to issue these regulations is based on title 49, section 30102(7) of the U.S. Code (formerly the National Traffic and Motor Vehicle Safety Act), the relevant part of which defines the term 'motor vehicle equipment' as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component or as any accessory, or addition to a motor vehicle . . . (emphasis added). Although you appear to recognize the applicability of our regulations, based on your characterization of your product as 'after market equipment,' allow me to explain how NHTSA determines whether an item of equipment is considered an accessory under the U.S. Code. The agency applies two criteria. The first criterion is whether a substantial portion of its expected uses are related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an 'accessory' and thus subject to the provisions of the U.S. Code. Your bag holder appears to be an accessory and thus an item of motor vehicle equipment under our regulations. It appears to be designed specifically to fit in motor vehicles using the head restraints, meaning that a substantial portion of its expected use relates to motor vehicle operation. The bag holder would typically be purchased and used by ordinary users of motor vehicles (i.e., anyone using the vehicle). While your bag holder is an item of motor vehicle equipment, NHTSA has not issued any standards for such an item. However, you as a manufacturer of motor vehicle equipment are subject to the requirements in sections 30118-30122 of Title 49 of the U.S. Code concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the product contains a safety related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Although no standards apply directly to the bag holder, there are other provisions of law that may affect the manufacture and sale of your product. NHTSA has issued a safety standard (Standard No. 201, Occupant protection in interior impact) that requires, among other things, that seat backs have a certain amount of cushioning to provide protection when struck by the head of rear seat passengers during a crash. Installation of your product on the back of front seats could have an impact on compliance with that standard. If your bag holder were installed so that a hard object (e.g., the rigid plastic hook) were to be struck by the occupant's head, the requisite amount of cushioning might not be achieved. We do not know how big or how 'rigid' the hook is, but it is something of which you should be aware. Other legal requirements could apply depending on how your product is marketed. If your product were installed by a vehicle manufacturer as original equipment, the vehicle manufacturer would have to certify that the vehicle with the bag holder installed complies with all FMVSS's, including Standard No. 201. In addition, although we recognize it would be unlikely that your product would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, section 30122(b) of title 49 prohibits those commercial businesses from 'knowingly mak ing inoperative any part of a device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard . . .' For instance, compliance with Standard No. 201 might be degraded if the bag holder were mounted in front of rear seat passengers. Any violation of this 'make inoperative' prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. The 'make inoperative' prohibition does not apply to modifications that vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your bag holder in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, NHTSA encourages vehicle owners not to degrade any safety device or system installed in their vehicles. In addition, individual States have the authority to regulate modifications that individual vehicle owners may make to their vehicles, so you might wish to consult State regulations to see whether your device would be permitted. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Mr. Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure";

ID: aiam1613

Dear Mr. Stallsmith: This responds to your September 24, 1974, question whether Standard No 121, *Air brake systems*, would apply to trailers manufactured prior to January 1, 1975, although the painting of the trailers and their delivery to Southern had not been completed.; Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Ac of 1966 provides:; >>>(a) No person shall -- (1) manufacture for sale, sell . . . any motor vehicle . . manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this subchapter unless it is in conformity with such standard . . .<<<; We consider a vehicle to be 'manufactured' for purposes of the Ac where the vehicle has been completed in all respects except for the addition of readily attachable components or minor finishing operations such as painting undertaken at a later date. A discussion of this point appears in the preamble to a recent Standard No. 121 rulemaking action (39 FR 17564, May 17, 1974). As for possession of the trailers by Southern, delivery of the vehicle is not considered a (sic) element of the manufacturing process.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam1615

Dear Mr. Stallsmith: This responds to your September 24, 1974, question whether Standard No 121, *Air brake systems*, would apply to trailers manufactured prior to January 1, 1975, although the painting of the trailers and their delivery to Southern had not been completed.; Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Ac of 1966 provides:; >>>(a) No person shall -- (1) manufacture for sale, sell . . . any motor vehicle . . manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this subchapter unless it is in conformity with such standard . . .<<<; We consider a vehicle to be 'manufactured' for purposes of the Ac where the vehicle has been completed in all respects except for the addition of readily attachable components or minor finishing operations such as painting undertaken at a later date. A discussion of this point appears in the preamble to a recent Standard No. 121 rulemaking action (39 FR 17564, May 17, 1974). As for possession of the trailers by Southern, delivery of the vehicle is not considered a element of the manufacturing process.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam1579

Dear Mr. Tsukano:#This responds to your August 1, and July 30, 1974 request for approval of hydraulic and vacuum brake hose labeling. We have evaluated your examples based on the labeling requirements of the standard as amended by Notice 11 of Docket No. 1-5.#The hydraulic brake hose marking on 'Face A' appears to conform to the requirements of S5.2.2, assuming that letter 'size' refers to letter height. The interval between markings, represented by '--', also conform. 'Face B' is not regulated by our standard.#With regard to the markings for brake hose end fittings, the date (indicated by 'XY') is not required. If you choose to add the date to your markings, it should not interfere with the legibility of the required markings. I would like to point out that under Notice 11, the marking requirements do not apply to end fittings 'attached by deformation of the fitting about a hose crimping or swaging.' This means that hydraulic hose fittings for use in passenger cars need not be labeled.#The brake hose assembly markings you submit appear to conform to the requirements of the standard.#With regard to vacuum brake hose, your 'Face A' appears to conform to S5.2.2 if letter 'size' refers to letter height. S5.2.1 is not applicable and therefore the stripe is not required. 'Face B' is not regulated by our standard.#We have placed 'MRCC' on file as the manufacturer designation for your company. #Yours truly,Richard B. Dyson;

ID: nht76-2.46

DATE: 01/14/76

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 8, 1975, asking four questions, the answers to which would provide an interpretation of Standard No. 108 with respect to separation distance of a turn signal lamp from the nearest edge of a Type 2 headlamp.

SAE Standard J588d, Turn Signal Lamps, June 1966, incorporated by reference in Standard No. 108, requires in pertinent part that "The optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam . . . ." We agree with your opinion that the reference to filament center may have been added because of the difficulty of determining the location of the optical axis in certain instances. In the vast majority of cases, however the filament center is on the optical axis, and the addition of the provision assists in determining compliance with the requirement.

You have asked:

"1. Is the filament center always to be taken as the center of the optical axis?"

The answer to this question is no. In some instances the filament center will not be on the optical axis. When this is the case the standard is ambiguous as to whether distance is measured from the optical axis or the filament center. While we prefer the optical axis, under the present wording either must be viewed as legally supportable.

"2. Is the center of the emitted light always to be taken as the center of the optical axis?"

The answer is yes.

"3. If the answers to the above two questions are no, does the vehicle manufacturer have the choice as to which method is most favorable to him?"

Yes, because of the ambiguity the manufacturer may choose either the optical axis or filament center as the point of measurement.

"4. What is the optical axis of a two- or three- compartment lamp?"

The optical axis of a multi-compartment lamp is the center of the light emitted by the array, treated as a single complex light source. The "half-value" method you described in your letter is a valid method of finding the optical axis of a complex light source as well as that of a simple one.

Finally you have asked whether, if we agree with the need for clarification, the letter can be considered a petition for rulemaking or whether a formal petition should be submitted.

We agree that clarification is needed and accordingly plan to issue a notice of proposed rulemaking in the near future.

Yours truly,

ATTACH.

December 8, 1975

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Berndt:

When inspecting 1976 passenger cars, we discovered a problem in measuring the distance of a front turn signal lamp from the nearest edge of the Type 2 headlamp. Federal Standard No. 108 requires that turn signal lamps meet the 4-inch minimum spacing in SAE J588d. Standard No. 108 also permits lamps to be mounted closer than the 4-inch interval if they emit 2-1/2 times the minimum candlepower otherwise specified.

SAE J588d clearly states that the distance shall be measured from the optical axis of the turn signal lamp to the inside diameter of the retaining ring from the headlamp providing the low beam. It then, unfortunately, makes the requirement ambiguous by a parenthetical reference to the filament center.

The SAE wording was satisfactory when it was adopted a number of years ago, because lamp designs then had the optical axis coincident with the filament. More recent designs have kept the filament 4 inches from the headlamp but have used the ambiguity as a loophole to allow the optical axis to be unreasonably close to the headlamp.

The 4-inch separation was adopted by SAE after a number of complaints about the lack of effectiveness of some turn signals that were snuggled up against the headlamps. The brightness of the adjacent low beam headlamps washed out the turn signals so they would not attract an oncoming driver's attention unless he was looking almost directly at them. The SAE Lighting Committee made nighttime demonstrations of turn signals at various distances from the headlamps in view of a proposal that the edges of the lamps be separated by a minimum distance such as 2 or 2 inches. A jury-type judgment indicated that the present requirement was barely acceptable usually and would allow vehicle manufacturers sufficient design freedom in placing the lamps on vehicles.

The attached drawing illustrates the absurdity of the "filament center" interpretation for modern-day turn signals (and incidentally the skill and ingenuity of lamp designers). Figure I shows a current lamp with a filament center meeting the 4-inch requirement but with an optical center much closer to the headlamp. Figure II illustrates a left-hand version of the same lamp with a filament center that does not meet the 4-inch requirement but with an optical center farther removed from the headlamp. The second lamp provides a more effective signal from an opposing driver's viewpoint, but it would be illegal if measured from the filament center.

The filament center reference apparently was added to the SAE standard because of an assumed difficulty in determining the location of the optical axis. An axis of any object usually passes through a point of symmetry. In the case of a symmetrical light beam meeting turn signal photometric requirements, the optical axis falls in a plane on either side of which is one-half of the total light output. The optical axis is easily located by measuring the intensity of the lamp at HV and then sliding an opaque card with a straight edge across the face of the lens until the photometer reading is one-half the HV value.

In view of the foregoing discussion, we would appreciate your interpretation of Standard No. 108 with respect to the following questions:

1. Is the filament center always to be taken as the center of the optical axis?

2. Is the center of the emitted light always to be taken as the center of the optical axis?

3. If the answers to the above two questions are no, does the vehicle manufacturer have the choice of which method is most favorable to him?

4. What is the optical axis of a two- or three-compartment lamp?

If you agree with the need for clarification, can this letter be considered a basis for your initiating a proposed change in Standard No. 108 or must this Department submit a formal petition for a rulemaking?

Very truly yours,

WARREN M. HEATH -- Commander, Enforcement Services Division

Enclosure

cc: Lou Owen, NHTSA; Francis Armstrong, NHTSA

(Graphics omitted)