ID: nht89-3.32

TYPE: INTERPRETATION-NHTSA

DATE: 11/06/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: S. WATANABE -- MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC CO., LTD., JAPAN

TITLE: NONE

TEXT: Dear Mr. Watanabe:

This is in reply to your FAX of September 14, 1989, asking for an interpretation of Motor Vehicle Safety Standard No. 108, with respect to a vehicle headlamp aiming device (VHAD), as shown in the drawing attached to your letter.

You have two questions:

"1) Does a VHAD without a function which compensates the deviation of floor slope satisfy FMVSS No. 108 S7.7.5.2(a)(1)(v)?"

Paragraph S7.7.5.2(a)(v) states that "Means shall be provided in the VHAD for compensating for deviations in floor slope not less than 1.2 degrees from the horizontal that would affect the correct positioning of the headlamp for vertical aim." If a VHAD is "without a function which compensates the deviation of floor slope" it would not satisfy Standard No. 108.

"2) This Head Lamp is designed to be aimed vertically by means of observing only one spirit level placed on the movable reflector, as shown in the drawing. Does this structure of VHAD satisfy FMVSS No. 108 S7.7.5.2(a)(1)(v)?"

The answer is yes, if observation of the simple spirit level is coordinated with an off-vehicle measurement of floor slope. As located, the spirit level with the range of +/- 1.2 degree range will allow aim of the headlamp, even though the vehicle may n ot be level, and will

compensate for floor slopes of up to 1.2 degrees, thus fulfilling the requirement that there be compensatory means when the vehicle upon which the headlamp is mounted is not resting upon level ground.

I hope that this answers your questions.

Sincerely,

[DIAGRAM OF VEHICLE HEADLAMP AIMING DEVICE OMITTED]

ID: nht76-2.42

DATE: 12/01/76 EST

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Koito Manufacturing Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 2, 1976, regarding questions on Docket No. 75-8; Notice 5, for a two-lamp rectangular headlamp system. The answers are provided in accordance with the paragraph numbering of your letter.

1) The two-lamp rectangular headlamps must meet the requirements of SAE J579c.

This is an improved performance lamp over the requirements of SAE J579a and, therefore, must meet the requirements of SAE J579c.

2) The maximum permissible candela for the Type 2B headlamp is 75,000 as specified in SAE J579c. The lower limit for other types of headlamps is retained awaiting future rulemaking action.

3) SAE J580b as specified in the 1976 edition of the SAE Handbook is the correct reference specification for the Type 2B Sealed Beam Headlamp Assembly.

3-1) Answered above

3-2) Answered above

3-3) Appropriate revisions to subreferenced SAE standards have at this time not been made for the Type 2B headlamp. In the case of SAE J580b, conducting the tests with a modified deflectometer to fit the Type 2B lamp would be sufficient. It is anticipated that revisions will soon be made to the appropriate subreferenced SAE standards for the Type 2B headlamp.

Your suggested revisions for the referenced and subreferenced SAE standards to incorporate the Type 2B headlamp, including a modified design of deflectometer, may be sent directly to:

Society of Automotive Engineers Detroit Office, Suite 206 2100 West Big (Illegible Word) Troy, Michigan 43084 ATTENTION: Mr. James Tishkowski

We hope this clarifies the questions contained in your letter. If you have additional questions, please do not hesitate to contact us.

ID: 2352y

Mr. T. Chikada
Manager, Automotive Engineering
Lighting 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 August 9, l989, to the former Chief Counsel, Erika Jones. You have asked for an interpretation of two of the amendments of May 9, 1989, to Federal Motor Vehicle Safety Standard No. l08. We have delayed answering you until action could be taken on petitions for reconsideration of the May 9 amendments. This action was taken on February 8, 1990 (copy of Federal Register notice enclosed), and the new amendments adopted then, effective March 12, l990, include definitions of "Direct reading indicator" and "Remote reading indicator."

Section S7.7.5.2(a)(l)(iii) states in pertinent part that each graduation on a Vehicle Headlamp Aiming Device (VHAD) "shall indicate a linear movement of the scale indicator of not less than 0.05 in. (1.27 mm) if a direct reading analog indicator is used," and "if a remote reading indicator is provided, it shall represent the actual aim movement in a clear, understandable format." Your letter depicts two devices identified as a "direct reading analog indicator" and a "remote reading indicator", and you ask for confirmation that each conforms with the requirements of the section.

Preliminarily, we observe that your drawings do not depict how the devices are determined to be "direct" and "remote". Our interpretation of your "direct indicator" is that the location of the bubble is proportional to the slope of the surface and the adjustment, i.e., as the angle of aim changes, so does the location of the bubble, and its location relative to the graduations changes in proportion to the angle of aim. Our interpretation of your "remote indicator" is that the location of the bubble represents the difference between the correct setting and the actual setting of the adjustment, and the reading may or mau not be proportional to the difference. Based on these interpretations, either device would appear to be capable of meeting the recently adopted definitions of direct and remote reading indicators.

For example, if either device were mounted in its entirety on the headlamp to sense vertical attitude, the devices would both appear to be capable of directly reading the aim of the headlap and also appear to be capable of accommodating variations in floor slope. In this case, each device would meet the definition of a "direct reading indicator". And if either device were mounted in whole or in part elsewhere than on the headlamp or its aiming or mounting equipment (e.g., mounted on the firewall, inner fender panel, instrument panel), and linked mechanically to the headlamp such that its vertical aim was correctly displayed on the indicator, each device would also appear to meet the definition of a "remote reading indicator".

Paragraph S7.7.2 requires in pertinent part that each headlamp aiming mechanism allow aim inspection and adjustment, and be accessible for such uses "without removal of vehicle parts, except for protective covers removable without the use of tools." You have asked whether the protective cover mentioned includes the cover to protect the spirit level when it is a component of the VHAD. The answer is no. The protective cover mentioned is one intended to shield the entire VHAD, or a cover that is not transparent and inhibits the proper aim inspection and adjustment. A transparent cover or transparent portions of a cover protecting the indicator (in your case, the spirit level of your direct reading indicator) is not required to be removable. However, if your remote reading indicator has a transparent protective cover, it would be required to be removable without the use of tools to gain access to the dial indicator, if the indicator is not adjustable with the cover in place.

I hope that this answers your questions.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosure ref:l08 d:3/l5/90

ID: nht90-1.70

TYPE: INTERPRETATION-NHTSA

DATE: 03/15/90

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: T. CHIKADA -- MANAGER, AUTOMOTIVE ENGINEERING LIGHTING CONTROL DEPT., STANLEY ELECTRIC CO. LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 8-9-89 TO ERIKA Z. JONES, NHTSA, FROM T. CHIKADA, STANLEY ELECTRIC CO., LTD., ATTACHED [OCC 3832]; ALSO ATTACHED FILE MEMO TO DOCKET SECTION FROM RICHARD L. VAN IDERSTINE, NHTSA, DATED JULY 21, 1989; [85-15-N08-011]

TEXT: This is in reply to your letter of August 9, 1989, to the former Chief Counsel, Erika Jones. You have asked for an interpretation of two of the amendments of May 9, 1989, to Federal Motor Vehicle Safety Standard No. 108. We have delayed answering you u ntil action could be taken on petitions for reconsideration of the May 9 amendments. This action was taken on February 8, 1990 (copy of Federal Register notice enclosed), and the new amendments adopted then, effective March 12, 1990, include definitions of "Direct reading indicator" and "Remote reading indicator."

Section S7.7.5.2(a)(1)(iii) states in pertinent part that each graduation on a Vehicle Headlamp Aiming Device (VHAD) "shall indicate a linear movement of the scale indicator of not less than 0.05 in. (1.27 mm) if a direct reading analog indicator is used ," and "if a remote reading indicator is provided, it shall represent the actual aim movement in a clear, understandable format." Your letter depicts two devices identified as a "direct reading analog indicator" and a "remote reading indicator", and you ask for confirmation that each conforms with the requirements of the section.

Preliminarily, we observe that your drawings do not depict how the devices are determined to be "direct" and "remote". Our interpretation of your "direct indicator" is that the location of the bubble is proportional to the slope of the surface and the a djustment, i.e., as the angle of aim changes, so does the location of the bubble, and its location relative to the graduations changes in proportion to the angle of aim. Our interpretation of your "remote indicator" is that the location of the bubble re presents the difference between the correct setting and the actual setting of the adjustment, and the reading may or mau not be proportional to the difference. Based on these interpretations, either device would appear to be capable of meeting the recen tly adopted definitions of direct and remote reading indicators.

For example, if either device were mounted in its entirety on the headlamp to sense vertical attitude, the devices would both appear to be capable of directly reading the aim of the headlap and also appear to be capable of accommodating variations in flo or slope. In this case, each device would meet the definition of a "direct reading indicator". And if either device were mounted in whole or in part elsewhere than on the headlamp or its aiming or mounting equipment (e.g., mounted on the firewall, inne r fender panel, instrument panel), and linked mechanically to the headlamp such that its vertical aim was correctly displayed on the indicator, each device would also appear to meet the definition of a "remote reading indicator".

Paragraph S7.7.2 requires in pertinent part that each headlamp aiming mechanism allow aim inspection and adjustment, and be accessible for such uses "without removal of vehicle parts, except for protective covers removable without the use of tools." You have asked whether the protective cover mentioned includes the cover to protect the spirit level when it is a component of the VHAD. The answer is no. The protective cover mentioned is one intended to shield the entire VHAD, or a cover that is not tran sparent and inhibits the proper aim inspection and adjustment. A transparent cover or transparent portions of a cover protecting the indicator (in your case, the spirit level of your direct reading indicator) is not required to be removable. However, i f your remote reading indicator has a transparent protective cover, it would be required to be removable without the use of tools to gain access to the dial indicator, if the indicator is not adjustable with the cover in place.

I hope that this answers your questions.

ENC.

ID: 19623.ztv

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

Dear Mr. Suzuki:

This is in reply to your letter concerning the testing of reflectors of replaceable lens headlamps for chemical and corrosion resistance. I apologize for the delay in our response.

Under the test procedure established by S8.10.1(c), after test fluids are applied to headlamp reflectors, the reflectors "shall be wiped clean with a soft cotton cloth . . . ." You remark that the force applied to the reflector during cleaning is not specified, noting that if Stanley wipes the reflector "so gently that the surface would not be damaged, the headlamp will meet the requirements prescribed in S7.4(h)(2)," but, "on the other hand, if we wipe the reflector without any carefulness, the surface might be damaged." In your opinion, this means that "some kind of attention is needed to meet the requirement of S7.4(h)(2)." You ask "if such kind of attention is permitted under S8.10.1(c)."

S5.8.11 of Standard No. 108 requires that a replacement lens for a replaceable lens headlamp must be provided with a replacement seal in a package "that includes instructions for the removal and replacement of the lens, the cleaning of the reflector, and the sealing of the replacement lens to the reflector assembly." Although you reference only the chemical resistance test of S8.10.1(c), we note that the corrosion test contains a specific requirement that "the reflector shall be cleaned according to the instructions supplied with the headlamp manufacturer's replacement lens" (S8.10.2(b)). The instructions for the cleaning of the reflector may specify the force recommended to be applied for this operation.

If the instructions do not specify the force needed to wipe the reflector clean, we would interpret the test procedure as encompassing the range of force levels that technicians would reasonably employ to perform the required task. Thus, in a compliance test where instructions are silent as to the force to be used, no special care would be taken to use the minimum possible force, nor would the technician deliberately use excessive force.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/29/99

ID: 1985-03.27

TYPE: INTERPRETATION-NHTSA

DATE: 08/09/85

FROM: JOHN LOVSTEDT -- HAWAII DOT MOTOR VEHICLE SAFETY OFFICE

TO: JERE MEDLIN -- OFFICE OF RULEMAKING NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/12/85 FROM ERIKA Z. JONES -- NHTSA TO LARRY HIROHATA, REDBOOK A28, STANDARD 108

TEXT: Dear Ms. Medlin:

We request a clarification to the final rule for modulating headlamps on motorcycles, which was published in the July 22, 1985, Federal Register.

The amendments to 49 CFR 571-108 shall permit the headlamps and side marker lamps to be wired to flash for signalling purposes. Does this mean that the headlamps on any motor vehicle can be wired to operate as a turn signal light in conjunction to general illumination of the area immediately ahead of the vehicle?

We question the requirement because the Society of Automotive Engineers (SAE) standard J580 defines a sealed beam headlamp assembly (J580, Section 2.1) as: "A major lighting assembly which includes one or more sealed beam units used to provide general illumination ahead of the vehicle". Also, SAE standards J588f, entitled, "Turn Signal Lamps" and J1221, entitled, "Headlamp - Turn Signal Spacing", both recommend that the spacing between the turn signal lamp and headlamp lower beam be at least four inches apart.

49 CFR, Section 393.22(b)(1), entitled, "Prohibited Combinations" (Federal Motor Carrier Safety Regulations, Bureau of Motor Carrier Safety) states in part: "A turn signal lamp must not be combined optically with either a headlamp or other lighting devices or combinatin of lighting devices that produces a greater intensity of light than the turn signal lamps."

Hence, we conclude that the headlamps of a motor vehicle should not be wired to incorporate the turn signal system or provide other functions when lamps are required to be illuminated during hours of darkness.

Your prompt response to this request is appreciated. Please send your response to:

Larry Hirohata

Vehicle Equipment Safety Specialist

Department of Transportation

Motor Vehicle Safety Office 79 South Nimitz Highway

Honolulu, Hawaii 96813

Thank you for your consideration.

Yours very truly,

ID: nht76-2.32

DATE: 07/23/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: R. H. Willcox, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 16, 1976, asking several questions with respect to the applicability of 15 USC 1397(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act and Federal Motor Vehicle Safety Standard No. 108 (49 CFR 571.108) to a product manufactured by your client, the W.B. Marvin Manufacturing Company. This product is "a screen which fits on the front part of the automobile and protects the radiator, headlamps and other lower parts of the car" from bugs.

W.B. Marvin would not be in violation of either the Act or Standard No. 108 by manufacturing and selling these screens. Such liability as may exist centers on the installation of them. Standard No. 108 establishes requirements for lighting equipment on new motor vehicles, and for replacement equipment. One of the requirements of SAE Standard J580a, Sealed Beam Headlamp, June 1966, incorporated by reference in Standard No. 108, is that "a headlamp, when in use, shall not have any styling or other feature, such as a glass cover or grille in front of the lens." Since the screen is positioned in front of the headlamps it would be an "other feature" of the type intended to be prohibited by the standard if, as appears likely, it affects compliance with headlamp photometrics (SAE Standard J579) or headlamp aim (SAE Standard J580). If installation results in a noncompliance, the screen could not, therefore, be legally installed by a vehicle manufacturer, distributor, or dealer as original equipment on a motor vehicle.

As for replacement equipment, under Section 1397 (a)(2)(A) of the Act an automobile owner may himself modify his vehicle in any manner he chooses, but modifications performed at his request by others may not "render inoperative in whole or part, any device or element of design installed on . . . a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard." If installation of the screen affects compliance with headlamp photometrics or other requirements, then it would appear to "render inoperative" a lighting device installed in accordance with a Federal motor vehicle safety standard, within the meaning of Section 1397(a)(2)(A). Installation by the auto service center of the retailer would therefore be prohibited, since such a facility is deemed a "motor vehicle repair business."

There are no Federal motor vehicle safety standards that directly apply to the screen as an item of motor vehicle equipment, nor do I know of any other Federal regulation affecting it.

I hope this letter is responsive to your questions.

YOURS TRULY,

CHESTER, HOFFMAN, PARK, WILLCOX & ROSE June 16, 1976

National Highway Traffic Safety Administration

Attention: Frank Berndt Acting Chief Counsel

Re: W. B. Marvin Manufacturing Co.

Our firm represents The W. B. Marvin Manufacturing Co. of Urbana, Ohio. They have contacted us concerning a product they wish to manufacture for use on automobiles which may involve the application of the Federal Motor Vehicle Safety Standards, particularly Standard 108 relating to headlamps. I personally have talked with Mr. Vinson of your office concerning the problem and he has advised me to write to you requesting an opinion concerning this situation. There is also a question as to the applicability of Section 108 of the National Traffic and Motor Vehicles Safety Act as amended in 1974.

The residents of south Florida have been bothered for years by the "lovebug" problem. These bugs appear in large numbers and accumulate on the headlamps and windshields and other parts of the cars driven on the south Florida highways. The W. B. Marvin Manufacturing Co. has designed a screen which fits on the front part of the automobile and protects the radiator, headlamps and other lower parts of the car from these bugs. At the same time, it is designed to direct the air flow in such a fashion that the bugs are diverted over the windshield so that they do not have an opportunity to come in contact with the windshield at all. This screen has been tested in Florida and had proved to be very successful. Pictures of the screen are enclosed for your information. The screen is designed for easy installation and removal. Tubes are attached to the front bumper of the car. The screen is attached to the car by sliding tubes affixed to the screen into the tubes affixed to the front bumper. Because of this design, the screen can be assembled relatively simply by the car owner or any auto service center. The car owner by himself may then mount the screen on the front of the car or remove it as required.

Without the screen, the bugs are plastered against the headlamps, thus affecting the amount of light coming from the headlamps. With the screen, the bugs will be on the screen, which is easily cleaned, rather than the headlamps. However, there is no question that when installed the screen will reduce the amount of light produced by the headlamps on to the roadway and this raises the question as to the applicability of the Federal Motor Vehicle Safety Standards and Section 108 of the National Traffic and Motor Vehicle Safety Act.

It is W. B. Marvin Manufacturing Company's intention to manufacture this screen and sell it to a retailer such as Sears Roebuck & Co. The retailer would sell the screen directly to the car owner who could either install it himself or have it installed at the retailer's auto service center.

Our client is ready to manufacture this screen and sell it to a retailer or retailers as described above. However, we do not want to advise them to proceed if the manufacturing of the screen or the manner in which the screen is sold and installed in any way violates any applicable Federal laws, rules or regulations. We are therefore requesting your opinion as to the applicability of the Federal Motor Vehicle Safety Standards and Section 108 of the National Traffic and Motor Vehicle Safety Act to the manufacture, sale and installation of this screen. In this regard, we raise the following questions: 1. Do the Federal Motor Vehicle Safety Standards and in particular, Standard 108, apply to this screen as manufactured by The W. B. Marvin Manufacturing Co.?

2. By manufacturing and selling the screen described above, is The W. B. Marvin Manufacturing Co. in violation of the Federal Motor Vehicle Safety Standards and in particular Standard 108?

3. By manufacturing and selling the screen as described above, is The W. B. Marvin Manufacturing Co. in violation of Section 108, Subparagraphs A (1) and A (2) of the National Traffic and Motor Vehicle Safety Act as amended in 1974?

4. Is there any violation of the Federal Motor Vehicle Safety Standards or Section 108 of the National Traffic and Motor Vehicle Safety Act if the screen in question is manufactured by W. B. Marvin Manufacturing Co., sold by them to a retailer such as Sears Roebuck & Co. and sold by the retailer to the automobile owner who installs the screen himself?

5. If the car owner purchases the screen from a retailer and has the screen installed at the retailer's auto service center, is the retailer and/or the manufacturer in violation of Section 108, Subparagraphs A (1) and A (2) of the National Traffic and Motor Vehicle Safety Act as amended in 1974?

6. Does the auto service center of the retailer constitute a "motor vehicle repair business" as used in Section 108, Subparagraphs A (2) (a) of the National Traffic and Motor Vehicle Safety Act?

7. Does the manufacturing, sale and installation of the screen in question come within the meaning of the phrase "render inoperative" as that phrase is used in Section 108, Subparagraph A (2) (a) of the National Traffic and Motor Vehicle Safety Act?

8. To your knowledge, are there any other Federal statutes or regulations which would prevent the manufacturing and sale of this screen?

As indicated before without the use of the screen the bugs will be plastered against the headlamps and windshield of the vehicle, thus affecting the visibility of the driver. With the screen, the bugs will be contained on the screen from which they can be easily removed and will be diverted over the windshield. In view of this, it does not appear to us that the use of the bug screen renders the vehicle less safe than without the screen. Therefore, if it is your opinion that Section 108 of the National Traffic and Motor Vehicle Safety Act is applicable to this situation, we hereby request that you exempt the manufacturer and the retailer from the application of Section 108.

If you need additional information, please call the undersigned and I will provide you with what you need if possible. Thank you for your consideration of this problem.

Roderick H. Willcox

(Graphics omitted)

ID: 15209.ztv

Mr. Steve Law
Magnet Marelli UK Ltd.
Lighting Division
Walkmill Lane, Cannock
Staffordshire
WS11 3LP
England

Dear Mr. Law:

This is in reply to your FAX of April 30, 1997, to Mr. Van Iderstine of this agency asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to "optical centre marking on visually aimable headlamps."

You present three drawings ("a," "b," and "c") of rectangular headlamps with various markings and ask are "any of these options mandatory/preferred/unacceptable."

Paragraph S7.8.5.3(f)(1) of Standard No. 108 requires that there "be a mark or markings identifying the optical axis of the headlamp," and that "[t]he manufacturer is free to choose the design of the mark or markings." Option "a" shows a marking in the center of the rectangle, whereas options (b) and (c) have four markings, one each at the center of each of the four sides.

With respect to your rectangular headlamp drawings, the optical axis runs directly through the center of the headlamp at 90 degrees to the lens face. This means that only option "a" identifies the optical axis of the rectangular headlamps. Options (b) and (c) are insufficient to identify the optical axis on the rectangular headlamp drawings and thus do not meet the requirements of paragraph S7.8.5.3(f)(1).

If you have further questions, you may refer them to Taylor Vinson of this office (FAX 202-366-3820).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.6/16/97

ID: 17323.ztv

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

Re: Headlamp light source arrangement

Dear Mr. Suzuki:

This is in reply to your letter of January 29, 1998, asking about the relationship of a planned replaceable light source headlamp system to Federal Motor Vehicle Safety Standard No. 108.

Paragraph S7.5(e)(2)(i)(A) specifies that the lower beam in a headlighting system may be provided "by the outboard light source (or the uppermost if arranged vertically) . . . ." In the system of interest to Stanley, the lower beam light source is placed above the upper beam light source but is also closer to the vehicle centerline than the upper beam light source. You have asked, in essence, whether this arrangement would comply with paragraph S7.5(e)(2)(i)(A).

This requirement originated with four-lamp headlamp sealed beam lighting systems in which headlamps were initially located side by side, with an identical horizontal centerline. Thus, the outboard specification was the one that was initially deemed most critical in drafting an amendment to Standard No. 108. However, when it was brought to the attention of the drafters that manufacturers intended to adopt four-lamp systems in which one lamp was mounted over the other, with an identical vertical centerline, the specification was proposed that the lower beam be provided by the upper lamp. The specification was applied to headlamp systems with replaceable light sources when these systems became permissible under Standard No. 108.

In Stanley's design, the two light sources do not have a common horizontal or vertical centerline. The horizontal centerline of the lower beam light source is 110 mm above that of the upper beam light source. Thus, the lower beam is clearly provided by the upper light source, in accordance with Standard No. 108. However, the vertical centerline of the lower beam light source is 20 mm inboard of that of the upper beam light source. That does not comport with the original intent of Standard No. 108 that the lower beam be provided by either the outermost lamp or by one with an identical vertical centerline to the upper beam lamp. In short, the lower beam light source must not only be the uppermost of the two light sources but, also, its vertical centerline must not be inboard of the vertical centerline of the upper beam light source. This means that Stanley's design does not comply with Standard No. 108.

Sincerely,
John Womack
Acting Chief Counsel
Ref:108
d.3/25/98

ID: nht93-5.20

TYPE: Interpretation-NHTSA

DATE: July 12, 1993

FROM: Cary Klingner -- Trison Inc.

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 from John Womack (signature by Kenneth N. Weinstein) to Cary Klingner (A41; Std. 108; VSA 108(a)(2)(A)h

TEXT:

TRISON INC. has developed a "Daytime Running Lights" module. The product keeps the low beam headlamps on whenever the vehicles engine is running. The module is placed under the hood and can be installed by any car owner. The unit is transparent to the vehicles lighting system thus allowing the headlamp and marking light switch to override it at any time. The product connects to the battery positive terminal, the highbeam headlamp, the lowbeam headlamp and one simply wraps around one spark plug wire.

The unit was developed because of the Minnesota law that requires headlamps to be on during daylight inclement weather. This law has created a problem in that some people forget to turn on their lights when required, or forget to turn them off when they leave their vehicle, which runs down the battery. Our unit will alleviate both problems if the driver does not override the module with the vehicle headlamp switch. The Minnesota law only requires that the headlamps be on so with our module no other lights or markers will be illuminated.

We understand that federal regulations were modified earlier this year that may affect this concept and we would like to market this product nationwide. Would you review our safety device and give us an opinion as to whether it complies with the regulations.

Thank you for your time, your response will be greatly appreciated.