ID: nht95-2.77

TYPE: INTERPRETATION-NHTSA

DATE: May 11, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Scott E. Mack -- Senior Product Manager, Philips Lighting Company

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM SCOTT E. MACK TO CHIEF COUNSEL, NHTSA (OCC 10269)

TEXT: Dear Mr. Mack:

This is in reply to your letter of April 24, 1995, requesting a confirmation of your interpretation that "Philips Color Clear (TM) Halogen Headlights . . . are in compliance with FMVSS-108."

The product in questions "appears to be colored when not in use" but "when lighted it produces white light as defined by J579C." You have provided a report from ETL Testing Laboratories which "indicates that the color of the light is identical to that of a standard halogen headlight."

There is no definition of white light in SAE J579c Sealed Beam Headlamp Units for Motor Vehicles, December 1978. We believe you mean SAE J578d Color Specification for Lighting Devices, September 1978 which does contain a definition expressed in chromati city coordinates. The report you supplied indicates that the Philips lamp provides a light within the color coordinates for white when equipped with a red, black, blue, or white insert. As Standard No. 108 contains no requirements for the color of glas s lamp lenses or bulbs, only the light emitted from the lamp, we confirm your conclusion that the Philips Color Clear (TM) headlamp has been designed to conform to the color requirements of Standard No. 108.

We appreciated your visit to NHTSA on April 26 to demonstrate the lamp with its various inserts. I understand that the light produced by the lamp, and by a standard headlamp, appeared identical to the naked eye in a side by side comparison.

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

ID: nht95-3.6

TYPE: INTERPRETATION-NHTSA

DATE: June 8, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

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

TITLE: NONE

ATTACHMT: ATTACHED TO 4/28/95 LETTER FROM R. F. TOLLEY TO CHIEF COUNSEL, NHTSA (OCC 10847)

TEXT: Dear Mr. Tolley:

This responds to your letter of April 28, 1995, asking for an interpretation of the torque deflection test specified in paragraph S7.8.5.1 of Motor Vehicle Safety Standard No. 108.

The second sentence of this paragraph states that "The downward force used to create the torque shall be applied parallel to the aiming reference plane, through the aiming pads, and displaced forward using a lever arm such that the force is applied on an axis that is perpendicular to the aiming reference plane and originates at the center of the aiming pad pattern." You believe that the instructions for performing the test are not sufficiently precise and can be interpreted in different ways. Specifica lly, you are concerned that the standard fails to adequately define the center of rotation of force, which is necessary to determine the downward force applied to the headlamp.

We agree with you, and are examining ways in which the standard might be amended to address the problem you have brought to our attention. Noting that you have presented four possible answers (as well as "some other point"), our comment is that; until N HTSA clarifies the matter, a manufacturer should choose a center of rotation that appears the most appropriate for the design of mechanically aimable headlamp under consideration, in certifying that the headlamp meets all applicable Federal motor vehicle safety standards.

I am sorry that we could not be more helpful at this point. If you have any questions you may refer them to Taylor Vinson of this office (202-366-5263).

ID: nht88-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 EST

FROM: N. BOWYER -- LAND ROVER UK LIMITED

TO: OFFICE OF THE CHIEF COUNSEL, NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/14/88 FROM ERIKA Z. JONES TO N. BOWYER; REDBOOK A32, STANDARD 208, 209 LETTER DATED 04/19/88 FROM D. BRUCE HENDERSON TO OFFICE OF GENERAL COUNSEL, NHTSA; OCC 1908

TEXT: Dear Sir,

I am writing on behalf of Land Rover UK Limited to request, from the National Highway Traffic Safety Administration, an interpretation of Federal Motor Vehicle Safety Standard No. 208 and No. 209. Land Rover UK Limited is a British company which markets its Range Rover model in the United States of America via its subsidiary, Range Rover of North America Inc.

On November 23, 1987, the NHTSA published a final rule amending FMVSS 208 - occupant crash protection. This final rule introduced dynamic test requirements for manual seat belts in both light trucks and multipurpose passenger vehicles. Part of this fina l rule introduced a new labelling requirement into FMVSS 209 - seat belt assemblies, and it is this requirement which we would like your interpretation on.

Paragraph S4.6.3. of FMVSS 208 is amended to read "a type of 2 seat belt assembly subject to the requirements of S4.6.1 or S4.6.2. (i.e. the dynamic test requirements) of this standard does not have to meet the requirements of S4.2(a) - (c) and S4.4. of Standard No. 209 (49CFR 571.209) of this part".

2

Paragraph S4.6(b) of FMVSS 209 is amended to read "a seat belt assembly that meets the requirements of S4.6. of the Standard No. 208 (49CFR 571.208) shall be permanently and legibly marked or labelled with the following statement: This dynamically tested seat belt assembly is for use only in (insert specific seating position(s), e.g. "front right") in (insert specific vehicle make(s) and model(s))".

These requirements appear to state that a manufacturer, at his option, can choose to fit seat belts which do not comply with some of the technical requirements of FMVSS 209, provided that they meet the dynamic test requirements of FMVSS 208. However, th ese amendments also imply that all seat belts which meet the dynamic test requirements must be labelled, in line with the amended FMVSS 209 requirements, regardless of whether or not they comply with all of the technical requirements of FMVSS 209.

Obviously, the NHTSA intended to ensure that seat belts which do not meet all the technical requirements of FMVSS 209, as allowed for in FMVSS 208, should be labelled, thereby ensuring that they are not installed into inappropriate vehicles. However, ou r reading is that the NHTSA did not intend the labelling requirements of FMVSS 209 to be applied to seat belts which comply with both the dynamic test requirements of FMVSS 208 and all of the technical requirements of FMVSS 209. After all, seat belts wh ich only comply with FMVSS 209 are not required to be labelled, so there is no reason to require seat belts which additionally meet the dynamic test requirements of FMVSS 208 need to be labelled. Is this not the correct interpretation of these requireme nts?

3

In considering this question, we would like to refer you to an NPRM which was issued by the NHTSA on December 29, 1987. This NPRM covers modifications to the headlamp requirements of FMVSS 108 and introduces a similar situation. The NPRM proposes simpl ifications to the headlamp requirements and also introduces a requirement that manufacturers supply information (i.e. part numbers) concerning the headlamps to the first purchaser. However, this NPRM proposes that the information is only supplied with v ehicles whose headlamps take advantage of the simplified requirements.

This example clearly indicates the intention to only require information on parts taking advantage of the relaxed requirements. Therefore, the labelling requirement of FMVSS 209 must be interpreted as follows:- 1) Dynamically tested seat belts which do not meet certain FMVSS 209 technical requirements, as allowed for in FMVSS 208, must be labelled in accordance with FMVSS 209 paragraph S4.6(b). 2) Dynamically tested seat belts which also comply with all of the technical requirements of FMVSS 209 need not meet the labelling requirements of FMVSS 209 paragraph S4.6(b).

If your interpretation is contrary to our understanding of the requirements, will you please treat this letter as a petition for rulemaking.

ID: aiam3840

Dear Mr. Haenchen: This is in reply to your letter of April 25, 1984, asking two question with respect to the humidity test for replaceable bulb headlamps specified in Motor Vehicle Safety Standard No. 108.; With reference to paragraph S6.8, you mention the relative humidit figure of 90 *+* 10 percent, and your interpretation that the six-hour cycle of the test should be run at 90 percent and that the 10 percent tolerance 'is intended to cover any drift in the instrumentation, controls and the process of generating this humidity.' We concur that this is a reasonable interpretation of this requirement.; You have also asked when the headlamp must be inspected after th humidity test, as paragraph S4.1.1.36(d)(7) is silent on this point. It is your interpretation that this inspection must occur directly following the test, and before the photometrics of the lamp are measured, even though, in your view, it would be more convenient to check it after the photometric test. Your interpretation is correct, this inspection must occur within the 9 to 11 minutes specified for beginning the photometric test after completion of the humidity test.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3292

Dear Mr. Milby:#This responds to your letter of January 16, 1980, i which you asked a number of questions pertaining to Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The answers to your questions are presented below and are numbered to correspond with the numbering of the questions in your letter.#1. Section 5.2.1 provides that where Table 1 of Standard 101-80 shows both a symbol and identifying words or abbreviations for a particular control, use of the symbol is mandatory and use of the words or abbreviations is optional.#2. When a manufacturer identifies a control with both the symbol shown in Table 1, Column 3, and the identifying words or abbreviations shown in Table 1, Column 2, only the symbol is subject to the illumination requirements of Section S5.3. That section states that with certain exceptions (i.e., foot operated controls or hand operated controls mounted upon the floor, floor console or steering column or in the windshield header area) 'the identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are actuated.' Since this section refers only to the identification required by Safety Standard 101-80, it does not apply to identification which is optional under the standard.#3., 4., 5., 6., 7., 8. In questions designated by these numbers, you asked whether the following controls are subject to the identification and illumination requirements of Standard 101-80:#>>>(a) a driver comfort fan which is not a part of the windshield or rear window defrosting and defogging system or the heating and air conditioning system,#(b) hot water flow valves for heaters which are opened in winter and then closed again in summer,#(c) heater fresh air control valves used to control the ratio of fresh to recirculated air entering the heater,#(d) driver's side window defroster control,#(e) driver's fresh air vent control,#(f) fan control for an optional driver's heater which directs air at the driver's feet.<<<#Section 5 of Standard 101-80 states that each vehicle that is subject to the standard and is manufactured with any control listed in Section 5.1 or in column 1 of Table 1 must comply with the requirements of Standard 101-80 regarding the location, identification and illumination of such control. Of the controls listed above, those lettered (a), (d) and (e) are not listed in either of these locations and thus are not subject to these requirements. Items (b), (c) and (f) are part of a heating or air conditioning system indicated in column 1 of Table 1 and is therefore subject to the location and identification requirements of Standard 101-80. However, the fan control, which directs air at the driver's feet, is not subject to the illumination requirements, since section 5.3.1 states, 'control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield.' Likewise, if the hot water flow valves and fresh air control valves are 'mounted upon the floor, floor console or steering column, or in the windshield header area,' then section 5.3.1 does not require them to be illuminated.#9. In your question 9, you asked whether the penultimate line in Table 2 concerning malfunctions in antilocks applies only to vehicles equipped with air brakes and whether the last line concerning brake system malfunctions applies only to vehicles equipped with hydraulic brakes.#The penultimate line of Table 2 applies to all vehicles less than 10,000 pounds GVWR which are equipped with an antilock system, regardless of whether they are air or hydraulic brake equipped vehicles. The agency included the reference to Standard 105, *Hydraulic Brake Systems*, to indicate that section 5.3 of that standard permits a manufacturer to use either a yellow or red warning light depending on whether there is a separate indicator that only warns of antilock failure or there is an indicator which warns of antilock and other brake system failures.#The last line of Table 2 concerning the telltale for brake system malfunction applies to all vehicles equipped with this type of telltale regardless of the type of brake system. The agency included the reference to Standard 105 since section 5.3 of that standard specifies other requirements that brake system malfunction indicators used in hydraulic brake systems must meet.#10. This agency has never established specific size requirements for the identification symbols specified in Tables 1 and 2 of Standard 101-80. Sections 5.2.1 and 6 only require that such symbols be visible to a driver restrained by crash protection equipment.#11. None of the display requirements of Table II of Standard 101-80 apply to vehicles with a GVWR exceeding 10,000 pounds. Displays included in such vehicles in accordance with other standards are subject only to the provisions of those standards.#12. Section 5.3.1 provides that the illumination requirements of Standard 101-80 do not apply to hand operated controls mounted on the steering column. Accordingly, they are not applicable to a hazard control mounted on the steering column.#13. If the clearance lamps are controlled with the headlamp switch, Table 1, footnote 2, of the standard provides that the only identification required is the headlamp switch symbol.#14. Standard 101-80, section 5.2.1, states that controls must be identified with the symbol indicated in Table 1 and that such identification shall be placed on or adjacent to the control. The agency has previously indicated that manufacturers could use a symbol that is a minor deviation from the required symbol, as long as the symbol used substantially resembles that specified in the standard (43 FR 27541, June 26, 1978). Thus, if the wiper symbol you want to use is only a minor deviation and substantially resembles the required wiper symbol, you may use it.#15. You enclosed in your letter a blueprint showing a bank of switches which control multispeed fans and asked whether the identification shown in the print would comply with the requirements of Standard 101-80. Since the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391) requires manufacturers to certify their compliance with all applicable Federal motor vehicle safety standards, this agency does not approve products. However, from our understanding of the information you have provided, it appears that the identification you propose to use for fan controls would comply with Standard 101-80. This opinion is based on the fact that your blueprint shows use of the fan symbol in accord with section 5.2.1 and identification of each function of the fan switch in accord with section 5.2.2.#16. With respect to air conditioning systems:#>>>(1) Section 5.3.1 does not require illumination of the control identification if the system does not direct air directly upon the windshield.#(2) Table 1 and section 5.2.1 require the fan symbol to be used to identify the fan for an air conditioning system,#(3) If the air conditioning system control regulates temperature over a quantitative range, the extreme positions must be identified in accord with 5.2.2.<<<#17. With respect to vehicles over 10,000 pounds GVWR, the requirements of Standard 101-80 concerning telltales used to indicate high engine coolant temperature or low engine oil pressure are inapplicable. With respect to vehicles less than 10,000 pounds GVWR, these requirements are applicable. In a letter to Ford Motor Company (copy enclosed), this agency stated that use of the engine symbol which Ford proposed for identification of such telltales would comply with the requirements of Standard 101-80.#Sincerely, Frank Berndt, Chief Counsel;

ID: aiam3293

Dear Mr. Milby:#This responds to your letter of January 16, 1980, i which you asked a number of questions pertaining to Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The answers to your questions are presented below and are numbered to correspond with the numbering of the questions in your letter.#1. Section 5.2.1 provides that where Table 1 of Standard 101-80 shows both a symbol and identifying words or abbreviations for a particular control, use of the symbol is mandatory and use of the words or abbreviations is optional.#2. When a manufacturer identifies a control with both the symbol shown in Table 1, Column 3, and the identifying words or abbreviations shown in Table 1, Column 2, only the symbol is subject to the illumination requirements of Section S5.3. That section states that with certain exceptions (i.e., foot operated controls or hand operated controls mounted upon the floor, floor console or steering column or in the windshield header area) 'the identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are actuated.' Since this section refers only to the identification required by Safety Standard 101-80, it does not apply to identification which is optional under the standard.#3., 4., 5., 6., 7., 8. In questions designated by these numbers, you asked whether the following controls are subject to the identification and illumination requirements of Standard 101-80:#>>>(a) a driver comfort fan which is not a part of the windshield or rear window defrosting and defogging system or the heating and air conditioning system,#(b) hot water flow valves for heaters which are opened in winter and then closed again in summer,#(c) heater fresh air control valves used to control the ratio of fresh to recirculated air entering the heater,#(d) driver's side window defroster control,#(e) driver's fresh air vent control,#(f) fan control for an optional driver's heater which directs air at the driver's feet.<<<#Section 5 of Standard 101-80 states that each vehicle that is subject to the standard and is manufactured with any control listed in Section 5.1 or in column 1 of Table 1 must comply with the requirements of Standard 101-80 regarding the location, identification and illumination of such control. Of the controls listed above, those lettered (a), (d) and (e) are not listed in either of these locations and thus are not subject to these requirements. Items (b), (c) and (f) are part of a heating or air conditioning system indicated in column 1 of Table 1 and is therefore subject to the location and identification requirements of Standard 101-80. However, the fan control, which directs air at the driver's feet, is not subject to the illumination requirements, since section 5.3.1 states, 'control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield.' Likewise, if the hot water flow valves and fresh air control valves are 'mounted upon the floor, floor console or steering column, or in the windshield header area,' then section 5.3.1 does not require them to be illuminated.#9. In your question 9, you asked whether the penultimate line in Table 2 concerning malfunctions in antilocks applies only to vehicles equipped with air brakes and whether the last line concerning brake system malfunctions applies only to vehicles equipped with hydraulic brakes.#The penultimate line of Table 2 applies to all vehicles less than 10,000 pounds GVWR which are equipped with an antilock system, regardless of whether they are air or hydraulic brake equipped vehicles. The agency included the reference to Standard 105, *Hydraulic Brake Systems*, to indicate that section 5.3 of that standard permits a manufacturer to use either a yellow or red warning light depending on whether there is a separate indicator that only warns of antilock failure or there is an indicator which warns of antilock and other brake system failures.#The last line of Table 2 concerning the telltale for brake system malfunction applies to all vehicles equipped with this type of telltale regardless of the type of brake system. The agency included the reference to Standard 105 since section 5.3 of that standard specifies other requirements that brake system malfunction indicators used in hydraulic brake systems must meet.#10. This agency has never established specific size requirements for the identification symbols specified in Tables 1 and 2 of Standard 101-80. Sections 5.2.1 and 6 only require that such symbols be visible to a driver restrained by crash protection equipment.#11. None of the display requirements of Table II of Standard 101-80 apply to vehicles with a GVWR exceeding 10,000 pounds. Displays included in such vehicles in accordance with other standards are subject only to the provisions of those standards.#12. Section 5.3.1 provides that the illumination requirements of Standard 101-80 do not apply to hand operated controls mounted on the steering column. Accordingly, they are not applicable to a hazard control mounted on the steering column.#13. If the clearance lamps are controlled with the headlamp switch, Table 1, footnote 2, of the standard provides that the only identification required is the headlamp switch symbol.#14. Standard 101-80, section 5.2.1, states that controls must be identified with the symbol indicated in Table 1 and that such identification shall be placed on or adjacent to the control. The agency has previously indicated that manufacturers could use a symbol that is a minor deviation from the required symbol, as long as the symbol used substantially resembles that specified in the standard (43 FR 27541, June 26, 1978). Thus, if the wiper symbol you want to use is only a minor deviation and substantially resembles the required wiper symbol, you may use it.#15. You enclosed in your letter a blueprint showing a bank of switches which control multispeed fans and asked whether the identification shown in the print would comply with the requirements of Standard 101-80. Since the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391) requires manufacturers to certify their compliance with all applicable Federal motor vehicle safety standards, this agency does not approve products. However, from our understanding of the information you have provided, it appears that the identification you propose to use for fan controls would comply with Standard 101-80. This opinion is based on the fact that your blueprint shows use of the fan symbol in accord with section 5.2.1 and identification of each function of the fan switch in accord with section 5.2.2.#16. With respect to air conditioning systems:#>>>(1) Section 5.3.1 does not require illumination of the control identification if the system does not direct air directly upon the windshield.#(2) Table 1 and section 5.2.1 require the fan symbol to be used to identify the fan for an air conditioning system,#(3) If the air conditioning system control regulates temperature over a quantitative range, the extreme positions must be identified in accord with 5.2.2.<<<#17. With respect to vehicles over 10,000 pounds GVWR, the requirements of Standard 101-80 concerning telltales used to indicate high engine coolant temperature or low engine oil pressure are inapplicable. With respect to vehicles less than 10,000 pounds GVWR, these requirements are applicable. In a letter to Ford Motor Company (copy enclosed), this agency stated that use of the engine symbol which Ford proposed for identification of such telltales would comply with the requirements of Standard 101-80.#Sincerely, Frank Berndt, Chief Counsel;

ID: 11606ZTV

Mr. J. Yoshimoto
Deputy General Manager
Technical Administration Department
Koito Mfg. Co. Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-Shi, Shizuoka-Ken
Japan

Dear Mr. Yoshimoto:

We have received your letter of February 9, 1996, asking for an interpretation of Motor Vehicle Safety Standard No. 108 and 49 CFR Part 564.

As you noted, the dimensional and specification information on HB Types of replaceable headlamp bulbs and their associated Figures were recently transferred from Standard No. 108 to Docket No. 93-11, established by Part 564. Note 2 to Figure 23-1 states that "It must be possible to insert the light source into a cylinder of diameter "s" concentric with the reference axis and limited at one end by a plane parallel to and 20 mm distant from the reference plane and at the other end by a hemisphere of radius s/2"

You asked whether the light shield is allowed to be located in the hatched area shown in Figure 23-1 and its note (2). You believe that the light shield may be located in the hatched area because the area is specified in order to allow room for the H4 yellow light source permitted by ECE REg. No. 37. However, there is no reason to allow room because yellow headlamps are not permitted under Standard No. 108.

Under Figure 23-1 and Note 2, no light shield may be located in the hatched area; therefore, we cannot agree with your interpretation. If Koito wishes to file a modified drawing to Docket 93-11 permitting installation of a light shield in the hatched area it may do so. However, in accordance with Sec. 564.5(d)(3) and (4), the changed drawing must be accompanied by

statements that the use of the light source as modified will not create a noncompliance with any requirement of Standard No. 108 when used to replace an unmodified light source in a headlamp certified by its manufacturer as conforming to Standard No. 108, and information demonstrating that the modification will not adversely affect interchangeability with the original light source.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:108 d:4/2/96

ID: 1986y

Mr. Takayoshi Chikada
Manager of Automotive Lighting
Engineering Control Dept.
Stanley Electric Co., Ltd.

FAX 03-792-0007 (Japan)

Dear Mr. Chikada:

This is in reply to your letter of June 16, l989, to Mr. Van Iderstine of this agency, by FAX as you requested. You have asked four questions with respect to the recently amended Federal Motor Vehicle Safety Standard No. l08.

We responded to your first two questions in a letter dated June l9 to Mr. Hasegawa of your office. A copy is enclosed for your reference. Since that time, however, in response to a petition by General Motors, we have changed the effective date of paragraph S7.7.5.1(a) to December l, l989, with respect to replaceable bulb headlamp systems. A copy of this notice is also enclosed.

Your third question is:

How should we prove the confirmation to the requirement of S7.7.2.2? We think the combination of Horizontal and Vertical angle within the aim range will be so huge and it is not practicable to test for all combinations.

This paragraph applies to headlamps aimed by moving the reflector relative to the lens and headlamp housing, or vice versa. The agency has frequently advised manufacturers that there is no legal requirement that conformance be demonstrated through the test procedures stated in the standard. While the agency will use those procedures in its compliance testing, the manufacturer may certify compliance with the performance requirements of a standard through engineering studies, computer simulations, mathematical calculations, or other means intended as an exercise of due care and affording a reasonable basis upon which to certify compliance. Your final question is:

It is acceptable to set up initial "0" point of S7.7.5.2(a)(2) not mechanically but photometrically?

You may determine the "O" point by whatever means you deem appropriate for the headlighting system, as long as the method achieves a horizontal "O" point that may be used for the purposes of paragraph S7.7.5.2(a)(2), and any other paragraph in which the horizontal "O" mark is required to be determined.

In the future, please address your requests for interpretations of Standard No. l08 to this office.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosure

ref:l08 d:8/23/89

ID: 77-3.3

TYPE: INTERPRETATION-NHTSA

DATE: 06/16/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Lucas Industries North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: 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,

Lucas Industries North America Inc

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.

Eric E Gough Staff Assistant (Technical) 21SA HEADLAMP BEAM SWITCH CIRCUIT

(Graphics omitted) (Illegible Text)

(Graphic omitted)

ID: aiam4609

FAX 03-792-0007 (Japan) Dear Mr. Hasegawa: This is in reply to your FA letter of May 22, l989, to Richard Van Iderstine of this agency. You have two questions with respect to the amendment to Standard No. l08 published on May 9, l989 (Docket No. 85-15, Notice 8). Your first question is the effective date of paragraph S7.7.5.1.(a), which you point out was not previously a requirement of Standard No. l08. You suggest the need for a delayed effective date (but give no reason why one may be needed). Paragraph S7.7.5.1(a) will be effective June 8, l989. Although the requirement is a new one (the restriction on motion of a headlamp when an external aiming device is applied to it), it was proposed as part of the December 29, l987 NPRM, and no comments received indicated a need for a delayed effective date. Your supposition is correct, S7.5.5.1 will apply to all headlamps with an external aiming system, including those incorporating replaceable bulbs. Your second question relates to paragraph S7.7.5.l(b), and you ask 'whether the requirement of '0.1 in. max.' will be determined, either during the test or after the test'. In pertinent part, subsection (b) states 'nor shall the lamp recede more than 0.1 in. (2.5 mm) after being subjected to an inward force....' This means that the measurement is determined after the test. Sincerely, Stephen P. Wood Acting Chief Counsel /;