ID: nht94-2.53

TYPE: INTERPRETATION-NHTSA

DATE: April 21, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Frank Williams -- President, Safety Brake Set

TITLE: None

ATTACHMT: Attached To Letter Dated 10/8/93 To NHTSA From Frank Williams (OCC-9219)

TEXT: Dear Mr. Williams:

This responds to your letter requesting information about Federal requirements related to a product that "sets the brakes on an air brake vehicle when the driver exits the cab." I apologize for the delay in our response. You stated that your "device doe s not hook into the brake system but pops the parking button out if the driver is off the seat and the door is open. The brake then must be manually disengaged." You requested confirmation that the agency will neither support nor oppose the aftermarket installation of such a device.

I am pleased to have this opportunity to explain our regulations to you. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, the National Highway Traffic Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufa cturer to ensure that its vehicles or equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.

NHTSA does not have any specific regulations about a product such as your device. However, since this device is related to a vehicle's air brake system, it could affect a vehicle's compliance with Standard No. 121, Air Brake Systems. That standard appli es to almost all new trucks, buses, and trailers equipped with air brake systems.

If your system is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 121. ( See 15 U.S.C. @ 1397(a)(1) and 49 CFR Part

2

567). If the device is added to a previously certified new motor vehicle prior to its first consumer purchase, then the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. 49 CFR @ 567.7.

If the device is installed on a used vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, then the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingl y render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. 15 U.S.C. @ 1397(a)(2)(A). In parti cular, these entities should ensure that the installation of your device does not render inoperative the vehicle's compliance with the parking brake requirements set forth in S5.6.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin-Shaw at this address or by telephone at (202) 366-2992.

Sincerely,

Enclosure

ID: nht94-6.16

DATE: April 21, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Frank Williams -- President, Safety Brake Set

TITLE: None

ATTACHMT: Attached To Letter Dated 10/8/93 To NHTSA From Frank Williams (OCC-9219)

TEXT: Dear Mr. Williams:

This responds to your letter requesting information about Federal requirements related to a product that "sets the brakes on an air brake vehicle when the driver exits the cab." I apologize for the delay in our response. You stated that your "device does not hook into the brake system but pops the parking button out if the driver is off the seat and the door is open. The brake then must be manually disengaged." You requested confirmation that the agency will neither support nor oppose the aftermarket installation of such a device.

I am pleased to have this opportunity to explain our regulations to you. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, the National Highway Traffic Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.

NHTSA does not have any specific regulations about a product such as your device. However, since this device is related to a vehicle's air brake system, it could affect a vehicle's compliance with Standard No. 121, Air Brake Systems. That standard applies to almost all new trucks, buses, and trailers equipped with air brake systems.

If your system is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 121. (See 15 U.S.C. @ 1397(a)(1) and 49 CFR Part

2

567). If the device is added to a previously certified new motor vehicle prior to its first consumer purchase, then the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. 49 CFR @ 567.7.

If the device is installed on a used vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, then the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. 15 U.S.C. @ 1397(a)(2)(A). In particular, these entities should ensure that the installation of your device does not render inoperative the vehicle's compliance with the parking brake requirements set forth in S5.6.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin-Shaw at this address or by telephone at (202) 366-2992.

Sincerely,

Enclosure

ID: 9219

Mr. Frank Williams
President
Safety Brake Set
3508 Cascade Highway
Silverton, OR 97381

Dear Mr. Williams:

This responds to your letter requesting information about Federal requirements related to a product that "sets the brakes on an air brake vehicle when the driver exits the cab." I apologize for the delay in our response. You stated that your "device does not hook into the brake system but pops the parking button out if the driver is off the seat and the door is open. The brake then must be manually disengaged." You requested confirmation that the agency will neither support nor oppose the aftermarket installation of such a device.

I am pleased to have this opportunity to explain our regulations to you. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, the National Highway Traffic Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.

NHTSA does not have any specific regulations about a product such as your device. However, since this device is related to a vehicle's air brake system, it could affect a vehicle's compliance with Standard No. 121, Air Brake Systems. That standard applies to almost all new trucks, buses, and trailers equipped with air brake systems.

If your system is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 121. (See 15 U.S.C. 1397(a)(1) and 49 CFR Part 567). If the device is added to a previously certified new motor vehicle prior to its first consumer purchase, then the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. 49 CFR 567.7.

If the device is installed on a used vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, then the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. 15 U.S.C. 1397(a)(2)(A). In particular, these entities should ensure that the installation of your device does not render inoperative the vehicle's compliance with the parking brake requirements set forth in S5.6.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:121 d:4/21/94

ID: 7200

Mr. Neil Friedkin
Attorney at Law
325 Exterior Street
Bronx, NY 10451

Dear Mr. Friedkin:

This responds to your follow-up letter to the agency requesting that the agency provide "the applicable 1986 standard for convertible passenger cars." In an earlier letter, you had asked about our regulations with respect to converting a vehicle from a hardtop to a convertible. I am pleased to have this opportunity to respond to your inquiry.

To begin, there is no single standard applicable to convertible passenger cars, or any other motor vehicles. Instead, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.; Safety Act) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. We have exercised this authority to establish many standards that apply to passenger cars, including convertible passenger cars. These standards, which are collectively called the Federal motor vehicle safety standards, are set forth in 49 CFR Part 571. They cover many different vehicle systems, including controls and displays, vehicle lighting, braking, occupant crash protection, and fuel system integrity.

As you review the safety standards in Part 571 to see which aspects of performance are of particular interest to you, you will see that the standards are generally identical for passenger cars and convertible passenger cars. There are some differences, however, including the permissible location for the center high mounted stop lamp (S5.3.1.8 of Standard No. 108, Lamps, Reflective Devices and Associated Equipment) and the inapplicability of the roof crush standard to convertibles (S3 of Standard No. 216, Roof Crush Resistance). Additionally, Standard No. 208, Occupant Crash Protection, required the front outboard seating positions of 1986 passenger cars that were not equipped with automatic crash protection (either air bags or automatic belts) to be equipped with a lap/shoulder belt and all other seating positions to be equipped with either a lap belt or a lap/shoulder belt (S4.1.2.3.1 of Standard No. 208). However, convertible passenger cars were permitted to offer either a lap belt or a lap/shoulder belt at every designated seating position, including the front outboard positions (S4.1.2.3.2 of Standard No. 208.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Ref:108#208#216 d:6/l5/92

ID: nht92-6.7

DATE: June 15, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Neil Friedkin -- Attorney at Law

TITLE: None

ATTACHMT: Attached to letter dated 4/16/92 from Neil Friedkin to Marvin Shaw (OCC 7200)

TEXT:

This responds to your follow-up letter to the agency requesting that the agency provide "the applicable 1986 standard for convertible passenger cars." In an earlier letter, you had asked about our regulations with respect to converting a vehicle from a hardtop to a convertible. I am pleased to have this opportunity to respond to your inquiry.

To begin, there is no single standard applicable to convertible passenger cars, or any other motor vehicles. Instead, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.; Safety Act) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. We have exercised this authority to establish many standards that apply to passenger cars, including convertible passenger cars. These standards, which are collectively called the Federal motor vehicle safety standards, are set forth in 49 CFR Part 571. They cover many different vehicle systems, including controls and displays, vehicle lighting, braking, occupant crash protection, and fuel system integrity.

As you review the safety standards in Part 571 to see which aspects of performance are of particular interest to you, you will see that the standards are generally identical for passenger cars and convertible passenger cars. There are some differences, however, including the permissible location for the center high mounted stop lamp (S5.3.1.8 of Standard No. 108, Lamps, Reflective Devices and Associated Equipment) and the inapplicability of the roof crush standard to convertibles (S3 of Standard No. 216, Roof Crush Resistance). Additionally, Standard No. 208, Occupant Crash Protection, required the front outboard seating positions of 1986 passenger cars that were not equipped with automatic crash protection (either air bags or automatic belts) to be equipped with either a lap/shoulder belt and all other seating positions to be equipped with either a lap belt or a lap/shoulder belt (S4.1.2.3.1 of Standard No. 208). However, convertible passenger cars were permitted to offer either a lap belt or a lap/shoulder belt at every designated seating position, including the front outboard positions (S4.1.2.3.2 of Standard No. 208).

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at

(202) 366-2992.

ID: nht88-4.26

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88

FROM: RICHARD L. STORY

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER 04/03/89, FROM ERIKA Z. JONES -- NHTSA TO RICHARD L. STORY, REDBOOK A33, STANDARD 218

TEXT: Gentleman

I would like to obtain some information form the NHTSA.

I purchased a 1988 Ford Thunderbird, in the rear seats the car has brackets for shoulder harness.

I contacted the dealer which I purchased the car from and asked to have the shoulder harness installed I was advised that their was a cost of $ 350.000 to do this.

I once saw a TV program on seat belth and traffic safety which stated this was to be installed in a auto by the car company at no charge to the auto owner.

I would like to know if their is a law that does state the car company must do this, if so could you please advise me on this and who I would contact in Ford Motor Company to have the shoulder harness installed. Thank you.

sincerely

ID: nht70-2.14

DATE: 06/22/70

FROM: AUTHOR UNAVAILABLE; R.A. Diaz; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, 1970, requesting approval of an equivalent test procedure for interior compartment doors, in place of those specified in S3.3.1(a) and (c) of Standard No. 201.

Since the phrase "approved equivalent test procedure" appeared in the initial Federal motor vehicle safety standards, the Bureau's position on this subject has undergone some clarification. The manufacturer's primary responsibility is to produce vehicles or equipment that, when tested according to the applicable standards, meet the stated requirements. Although a manufacturer is responsible for ensuring that his products meet all the requirements of the standards, there is nothing in the Act that requires a manufacturer to perform any predetermined series of tests. If a particular test is actually "equivalent" to the procedure described in the standard, in the sense that the test results can be accurately correlated to the standard's requirements, there is no need to request approval of the Bureau, and there would be no legal significance to the approval if given. Conversely, if the test is not equivalent, so that an item that "possed" the test might still fail to conform to the standard, the request would be actually for a lowering of the standard, which could not be done without rulemaking procedures. For this reason, we will not grant the approval in the form in which it was requested.

The procedure that you described does, however, appear to be a distinct improvement in the method of testing this aspect of performance. We intend to initiate rulemaking procedures directed at amending the standard to incorporate that test.

ID: nht75-1.31

DATE: 06/10/75

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of December 12, 1974, requesting an interpretation of the definition of "permanently attached end fitting" appearing in Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

You have described a process of heat shrinking plastic vacuum booster hose over short corrugated metal connecting tubes, the ends of which are flared to retain threaded hex fittings. You have submitted sample hose assemblies and requested confirmation of your interpretation that the end fittings are permanently attached. While these fittings may meet the common understanding of the words "permanently attached," Standard No. 106-74 defines "Permanently attached end fitting" as:

an end fitting that is attached by deformation of the fitting about the hose by crimping or swaging, or an end fitting that is attached by use of a sacrificial sleeve or ferrule that requires replacement each time a hose assembly is rebuilt.

Deformation of the hose about the fitting by heat shrinking is not "deformation of the fitting about the hose by crimping or swaging." The latter part of the definition is inapplicable because the assemblies are not subject to being rebuilt. Therefore, to classify these end fittings as permanently attached would require an amendment of the standard. Such an amendment is being considered.

Your January 7, 1975, petition for reconsideration, requesting exclusion of the above described vacuum hose from the coverage of Standard No. 106-74, was received more than 30 days after the most recent amendment of the definition of "brake hose". Therefore, it has been treated as a petition for rulemaking. The Standard defines "brake hose" as:

a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.

The conduit between the vacuum booster and vacuum pump in your brake booster circuit clearly falls within this definition, and hence is subject to the Standard's requirements. The NHTSA has concluded that, because of its flexibility, this hose is exposed to the same hazards as the more traditional types of vacuum brake hose and so should be subject to the same performance requirements. Accordingly, your petition to amend the definition is denied. The conduit between the vacuum pump and the intake manifold, however, falls outside the definition of "brake hose" because, as described by Mr. Craig Jones in a conversation with Mr. Howard Dugoff of this agency on March 17, 1975, the booster system produces full vacuum even when this conduit fails. Therefore, this conduit need not comply with the requirements of Standard No. 106-74.

Sincerely,

ATTACH.

MERCEDES-BENZ OF NORTH AMERICA, INC.

December 12, 1974

Office of Chief Counsel National Highway Traffic Safety Administration

Subject: Brake Hoses

Gentlemen:

Federal Motor Vehicle Safety Standard 106; Brake Hoses, defines under Section S4 a "permanently attached end fitting" as being a fitting that is attached by deformation of the fitting about the hose by crimping or swaging or an end fitting that is attached by use of a sacrificial sleeve or ferrule that requires replacement each time a hose assembly is rebuilt.

Vacuum booster circuit conduit can be constructed with materials and techniques so as to satisfy, what we believe to be, the intent of this definition. Specifically, thermoset plastic materials can be heat shrunk over corrugated connections at end fittings and mid-circuit devices such as check valves. Additionally, threaded hex fittings can be secured to metal end pipes by means of flaring. These construction techniques not only provide satisfactory performance but result in an assembly that cannot be disassembled without the disstruction of one or all of the various components. Examples of these construction techniques have been forwarded to the Docket Room.

These assemblies as used on Mercedes-Benz vehicles are completely and finally assembled by our suppliers. Installation of these assemblies into our vehicles entails only the threading of the fittings into the various parts of the vacuum cricuit. There is no final construction of these hose assemblies in our manufacturing facilities. Additionally, these assemblies are offered for spare parts usage only as complete assemblies.

We hereby request clarification as to whether or not this type of vacuum conduit assembly construction satisfies the intent of the definition of permanently attached end fittings as used in this Standard and thereby permit banded identification of the complete assembly rather than a separate identification of each component.

Should you require additional information or material to clarify this request, do not hesitate in contacting this office.

Very truly yours,

Heinz W. Gerth Assistant Vice President Engineering

MERCEDES-BENZ OF NORTH AMERICA, INC.

January 7, 1975

Office of The Chief Council National Highway Traffic Safety Administration Subject: Petition for Reconsideration FMVSS 106, Brake Hose

Gentlemen:

Pursuant to discussions with Mr. Driver in Washington on July 26, 1974 and with Mr. Dugoff on November 4, 1974 during his visit to Germany, we would like to restate our position that the flexible vacuum conduit used in Mercedes-Benz passenger vehicles in the brake boost circuit does not fall within the definition of brake hose as outlined in Standard 106.

While this particular conduit may not satisfy the hose flexibility requirements of paragraphs S9.2.2, S9.2.3, S9.2.7 and S9.2.10, it does offer the important advantages of being resistant to high temperature and ageing.

Additionally, the installation in Mercedes-Benz vehicles is such that it is subject to very little vibration between the intake manifold and booster. The material was specifically chosen because its limited flexibility permits safer, simpler installation requiring fewer mounting brackets. The complete assembly, when installed, is still sufficiently rigid so as to prevent any abrasion, and in appearance is similar to tubing so that a mechanic will not be tempted to push it aside to gain more workspace.

A sample of this assembly has been forwarded to the Docket Section for review. Should you request additional material or information for this Petition for Reconsideration, please do not hesitate in contacting this office.

Very truly yours,

Heinz W. Gerth Assistant Vice President Engineering

ID: 16539.wkm

Mr. Donald W. Vierimaa
Vice President - Engineering
Truck Trailer Manufacturers Association
1020 Princess Street
Alexandria, VA 22314-2247

Dear Mr. Vierimaa:

Please pardon the delay in responding to your letter to Dr. Ricardo Martinez, the National Highway Traffic Safety Administration (NHTSA) Administrator, in which you referred to subsection S5.3, Federal Motor Vehicle Safety Standard (Standard) No. 120, Tire selection and rims for motor vehicles other than passenger cars (49 CFR 571.120), and asked whether kilograms and pounds can be abbreviated kg and lb respectively. The answer is yes.

Subsection S5.3, Label information, requires that each vehicle other than passenger cars shall show tire and rim labeling as specified in S5.3.1 and S5.3.2 respectively, "in the format set forth following this section." Examples of the required labeling are set forth following paragraph S5.3.2, entitled "TRUCK EXAMPLE -- SUITABLE TIRE-RIM CHOICE." In those examples the words "kilograms" and "pounds" are spelled out, with no indication that abbreviations may be used.

The labeling is required to be shown "in the format" set forth in the examples. In a denial of a petition for reconsideration and denial of a petition for rulemaking concerning our child seat standard published in the Federal Register on June 4, 1993 (58 FR 31658) (extract enclosed), NHTSA stated:

Format refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material.

Since no reference is made to the use of abbreviations, it is our opinion that the requirement that the specified labeling be "in the format" shown at the end of the section does not prohibit the use of appropriate abbreviations.

For the sake of brevity, NHTSA has always routinely used abbreviations throughout its standards, especially on prescribed labels. This saves scarce space on such labels and the more commonly used abbreviations, such as "kg" for kilograms and "lb" for pounds, are widely known and recognized by the public. Accordingly, those abbreviations are tantamount to the full spelling of those words and may be used interchangeably with the full spelling of those words in the labeling required by S5.3, Standard No. 120.

I hope this information is helpful to you. Should you have any questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992, fax (202) 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:120
d.3/19/98

ID: 1985-01.40

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

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

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada, Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

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

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

Sincerely,

Frank Berndt Chief Counsel

January 11, 1985

Attn: Mr. Taylor Vinson Lawyer

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

Dear Mr. Vinson,

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

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

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

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

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

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

Sincerely,

Stanley Electric Co., Ltd.

T. Chikada, Manager Automotive Lighting Engineering Control Dept.

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

Federal Motor Vehicle Safety Standard No.108

Lamps, reflective devices, and associated equipment

S1. Purpose and scope

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

S2. Application

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

S3. Definitions

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

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

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

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

S4. Requirements S4.1 Required motor vehicle lighting equipment

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

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

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

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

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

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