ID: 9889

Herr Tilman Spingler
Robert Bosch GmbH
Automotive Equipment Div. 2
Postfach 13 42
D-72703 Reutlingen
Germany

Dear Mr. Spingler:

This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems.

You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerning indivisibility and integration . . . ."

There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:5/5/94

ID: aiam3866

Dear Mr. Gill: This is in response to your letter of May 25, 1984, asking for a interpretation of Motor Vehicle Safety Standard No. 108. Table IV specifies that the minimum horizontal separation distance '(centerline to centerline of lamp)' for rear turn signal lamps on motorcycles is 9 inches. You have asked whether the 'centerline' refers to the distance between the lens centers, between the centers of the effective projected luminous areas, or between the bulb centers.; You asked for confirmation of your belief that the prope interpretation is found in the referenced SAE Standard, J588e, which contains the language 'Optical axes (filament centers),' implying that the correct distance is that between the 'bulb centers' as you term it.; We find no direct correlation between the phrases 'centerline t centerline of lamps' and 'optical axis (filament center).' The lamp is a device emitting light whereas 'optical axis (filament center)' does not refer to the lamp but only to a portion of its light-producing component. As that phrase is used in SAE J588e, it defines the method of measuring distances between bulbs in multi-compartment lamps for the purpose of testing for photometric requirements (paragraph 3.1), or in measuring the separation of the turn signal from the headlamp (paragraph 4.2, where, incidentally, it is expressed as the distance between filament and a lamp component, the retaining ring).; Taken literally, 'centerline to centerline of lamps' in our view mean the distance between lens centers. In the response to petitions for reconsideration of the center high-mounted stoplamp amendment (May 17, 1984), the question was asked whether the 'center' of the lamp was its geometric center, its optical center, or the center of the bulb filament. The agency replied that the center of the lamp is the geometric center. Since the purpose of the minimum separation requirement is to insure that the turn signal is perceived as such, we believe that the correct interpretation of 'centerline to centerline' is a measurement from the geometric center of one lamp to the geometric center of the other lamp. The geometric center would be synonymous with the term 'geometric centroid of lens' as used in SAE J1221 *Headlamp-Turn Signal Spacing*.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3144

Dear Mr. Young: This is in reply to your letter of September 24, 1979, to Mr. Vinson o this office in which you requested an interpretation S4.1.1.19 of Federal Motor Vehicle Safety Standard No. 108.; S4.1.1.19 states: >>>A lamp manufactured on or after January 1, 1974 and designed to us a type of bulb that has not been assigned a mean spherical candlepower rating by its manufacturer and is not listed in SAE Standard J573d 'Lamp Bulbs and Sealed Units', December 1968, shall meet the applicable requirements of this standard when used with any bulb of the type specified by the lamp manufacturer, operated at the bulb's design voltage. A lamp that contains a sealed-in bulb shall meet these requirements with the bulb operated at the bulb's design voltage.<<<; It is noted that this paragraph consists of two sentences. You hav asked whether the 'lamp' and 'bulb' of the second sentence are the same 'lamp and bulb' of the first sentence.; The answer is no. The first sentence would require testing, at th bulb's design voltage, of bulbs used in sealed beam headlamps but not of bulbs used in, for example, taillamps. The former, though listed in J573d (Table 2), is not assigned a mean spherical candlepower rating since these bulbs emit shaped beams while the latter is used in the sealed lamp, it is tested at the bulb's design voltage rather than using the rated mean spherical candlepower. Furthermore, the rulemaking history of the paragraph clearly indicates that the two requirements are separate. As the agency noted in the preamble to the proposal, 'The proposal specifies that when no rating has been assigned by the bulb manufacturer or the SAE *or* if the lamp is sealed and the bulb cannot be replaced, the bulb shall be operated at design voltage' (emphasis supplied) (38 FR 16230).; You noted that your question relates to the voltage required b Standard No. 108 for the photometric testing of a sealed beam headlamp that utilizes a European halogen bulb that meets ECE Regulation 37.; Since J579c requires the test voltage to be 12.8 volts for all th sealed beam bulbs, the photometric test should be at 12.8 volts and not at the so-called 'system voltage' of 12 volts.; I hope this is responsive to your request.

ID: 1985-03.40

TYPE: INTERPRETATION-NHTSA

DATE: 09/06/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

September 6, 1985 Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13, Nakamegura, Meguro-Ku Tokyo 153, Japan Dear Mr. Chikada: This is in response to your letter of June 27, 1985, to the former Chief Counsel of this agency, Frank Berndt, asking for an interpretation regarding Figure 4-1 of Motor Vehicle Safety Standard No. 108. With reference to a two-lamp system headlamp with two reflectors, you have asked which of three specified Points should be regarded as the "center of aiming pattern" within the meaning of Figure 4-1. The answer is Point B, of the center of the bulb for the lower beam. NHTSA provided a clarification of this in the final rule permitting two-bulb replaceable bulb headlighting systems, published on May 22, 1985. I enclose a copy for your information. In it, the agency remarked that "NHTSA expects the aiming pads to be located on the optical axis of the lower beam portion of the headlamp when only one light source is used for the lower beam." Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel Enclosure

ID: 77-2.9

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/77

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Dennis J. Mahr; Attorney at Law

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 23, 1977, letter asking whether Ford Motor Company's record keeping practices conform to the regulations of the National Highway Traffic Safety Administration (NHTSA).

Your letter refers to material allegedly destroyed by Ford pertaining to accident and recall information involving headlamp concealment devices in 1967 Mercury Cougars. The NHTSA is unable to ascertain from the information that you have submitted whether or not Ford's record keeping violates our requirements.

The NHTSA implemented on August 20, 1974, a regulation requiring manufacturers to retain for a period of 5 years records generated or acquired after August 15, 1969, concerning motor vehicle malfunctions that may be related to motor vehicle safety (49 CFR 576, Record Retention). Since the recall to which you refer occurred prior to this regulation, it is possible that the identified records were generated of acquired prior to the promulgation of the regulation, and therefore, the destruction of these records would not necessarily mean that Part 576 was violated.

The NHTSA has a public file concerning the headlamp concealment devices referred to in your letter. This file containing 26 pages of information will be sent to you by our Technical Reference Branch under separate cover.

ID: nht91-1.38

DATE: February 11, 1991

FROM: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc.

TO: Paul Jackson Rice -- Chief Council, NHTSA

TITLE: Re FMVSS Number 108, Lamps, Reflective Devices, and Associated Equipment

ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to Delbert N. Pier (A37; Std. 108)

TEXT:

Hyundai requests assistance with an interpretation regarding Federal Motor Vehicle Safety Standard, Number 108 (lamps, reflective devices, and associated equipment).

In regards to the interchangeability of headlamp bulbs, the procedure (571.108) requires that the terminals must be perpendicular to the base and parallel within plus or minus 1.5 degrees.

Hyundai would like an interpretation on whether the bulb fixture can be rotated approximately 11 degrees, as shown in the attachment, view X. This will not change the terminal logistics by the rotation of the bulb fixture. This rotation will not change the constants, (attachment, view Y, from 49 CFR) or the relationship of the terminals to the constants.

Hyundai is requesting an interpretation for a future production vehicle and needs a prompt answer. Thank you for your assistance in this matter. Should further clarification be required, feel free to contact me at the telephone number listed above.

Attachment 1

S571.108 49 CFR Ch. V (10-1-89) Interchangeability Drawing Headlamp Bulb Assembly (Text and graphics omitted)

ID: aiam5456

Dear Mr. Wright: This responds to your letter of July 15, 1994, t Robert Hellmuth of this agency requesting an opinion whether brush guards offered as accessories for Range Rovers and installed in front of headlamp units are in violation of Standard No. 108. Our letter is based upon the configurations of 'brush bars' depicted as accessory equipment in a 1994 Range Rover brochure. The brochure notes that brush bars 'may be illegal for on-road use in some states. Please check local regulations before purchase, installation, or use.' We note that this advisory applies to the rear lamp guards as well. The purpose of the brush bar is to offer protection to the grille, radiator, and front and rear lamps, and it does so by incorporating three slender horizontal bars in front of the lenses of the front and rear lamps. Paragraph S7.8.5 of Standard No. 108 states that headlamps when activated 'shall not have any styling ornament or other feature, such as a translucent cover or grille, in front of the lens.' The lamp guard portion of the brush bar is the type of 'other feature . . . in front of the lens' that is prohibited by Standard No. 108. Thus, under Federal law, a Range Rover could not be displayed for sale and sold with a brush bar installed unless the lamp guards had been removed. This should present no problem as, according to the brochure, the 'lamp protectors are easily removable for cleaning and maintenance.' In our view, the proper time for installation of the lamp protectors is when the vehicle begins to be used off-road. Although there is no similar direct prohibition in Standard No. 108 applicable to other vehicle lamps, the parking lamps, turn signal lamps, and rear lamps are required to conform with the photometric requirements of Standard No. 108 when the lamp guards are in place. This is based upon two paragraphs of the standard. S5.3.1.1 prohibits any part of a vehicle from preventing parking lamps, turn signal lamps, and rear lamps from meeting the required photometric output. S5.1.3 prohibits the installation of supplementary motor vehicle equipment that impairs the effectiveness of lighting equipment that Standard No. 108 requires as original equipment. The guards are designed for maintenance by the owner, and their installation by the owner after purchase of the Range Rover would not be in violation of Federal law, even if installed for on-road use. Operation of the Range Rover is subject only to State law, and a State may forbid on-road use of a Range Rover with the lamp guards installed if it so chooses. Sincerely, Philip R. Recht Chief Counsel;

ID: aiam2173

Dear Mr. Heath: This is in response to your letter of December 8, 1975, asking fou questions, the answers to which would provide an interpretation of Standard No. 108 with respect to separation distance of a turn signal lamp from the nearest edge of a Type 2 headlamp.; SAE Standard J588d, *Turn Signal Lamps*, June 1966, incorporated b reference in Standard No. 108, requires in pertinent part that 'The optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam . . . .' We agree with your opinion that the reference to filament center may have been added because of the difficulty of determining the location of the optical axis in certain instances. In the vast majority of cases, however the filament center is on the optical axis, and the addition of the provision assists in determining compliance with the requirement.; You have asked:>>> '1. Is the filament center always to be taken as the center of th optical axis?'<<<; The answer to this question is no. In some instances the filamen center will not be on the optical axis. When this is the case the standard is ambiguous as to whether distance is measured from the optical axis or the filament center. While we prefer the optical axis, under the present wording either must be viewed as legally supportable.>>>; '2. Is the center of the emitted light always to be taken as the cente of the optical axis?'<<<; The answer is yes.>>> '3. If the answers to the above two questions are no, does the vehicl manufacturer have the choice as to which method is most favorable to him?'<<<; Yes, because of the ambiguity the manufacturer may choose either th optical axis or filament center as the point of measurement.>>>; '4. What is the optical axis of a two- or three- compartment lamp?'<<< The optical axis of a multi-compartment lamp is the center of the ligh emitted by the array, treated as a single complex light source. The 'half-value' method you described in your letter is a valid method of finding the optical axis of a complex light source as well as that of a simple one.; Finally you have asked whether, if we agree with the need fo clarification, the letter can be considered a petition for rulemaking or whether a formal petition should be submitted.; We agree that clarification is needed and accordingly plan to issue notice of proposed rulemaking in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 15810.ztv

Kiyoshi Narabu, General Manager
Technical Department
Ichikoh Industries, Ltd.
80 Itado, Isehara
Kanagawa, 259-11
Japan

Dear Mr. Narabu:

This is in reply to your letter of August 19, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108, specifically, S7.8.3 and S7.8.4.

The first sentence of S7.8.3 states that "When a headlamp system is tested in a laboratory, the range of its vertical aim shall not be less than +/-4 degrees from the nominal correct aim position for the intended vehicle application." To the same effect is the first sentence of S7.8.4 which prescribes a horizonal aim tolerance of +/-2.5 degrees. You state that "there are no provisions that prescribe the aim range formed out of [the] vertical and horizontal axis," and submit four Figures of various aim range possibilities and ask whether they conform to Standard No. 108.

Your Figure 1 represents a literal interpretation of S7.8.3 and S7.8.4, depicting vertical and horizontal aim tolerances. However, these are not meant to be mutually exclusive. At any point within the +/- 4degree vertical aim the horizontal aim must be adjustable +/- 2.5 degrees and vice versa, in order to ensure that headlamp aim is correct over the broadest possible range within both the vertical and horizontal directions. This means that Figure 1, as we interpret it, does not represent the correct interpretation of S7.8.3 and S7.8.4 when these paragraphs are read together.

Figure 4 represents our interpretation of Standard No. 108 describing the full rectangle of aiming possibilities created by the plus and minus aspects of the vertical and horizontal aim tolerances. Because Figures 2 and 3 with their "lozenge" and "ellipse" aiming areas respectively do not cover the full range of horizontal aim over the full vertical range of +/- 4 degrees they do not represent a correct interpretation of Standard No. 108.

I hope that this answers your questions.

Sincerely,
John Womack
Acting Chief Counsel

ref:108

d.9/11/97

ID: 1985-01.48

TYPE: INTERPRETATION-NHTSA

DATE: 03/14/85 EST

FROM: BARRY FELRICE -- NHTSA RULEMAKING

TO: FRED W. BOWDITCH -- MVMA TECHNICAL AFFAIRS DIVISION

TITLE: NONE

ATTACHMT: LETTER DATED 10/29/84 FROM FRED W. BOWDITCH -- MVMA TO DIANE K. STEED -- NHTSA, PETITION

TEXT: Dear Mr. Bowditch:

On October 29, 1984, the Motor Vehicle Manufacturers Association filed a petition for rulemaking to amend Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The petition requested "removal from section 4.1.1.36(a) (2) of the limitation requiring the three aiming pads to be located on the exterior face of the headlamp lens." You have suggested the mounting flange at the lens-reflector joint as an acceptable alternative location for the aiming pads. The language suggested in the petition for amendment of S4.1.1.36(a) (2) would also allow all three legs to be adjustable on the headlamp aimers.

The agency has proposed amendments to Standard No. 108 (49 FR 47880) to delete the final sentence of paragraph S4.1.1.36(a) (2) with reference to aiming locating plates, and to delete Figures 9-1 and 9-2. Thus, this aspect of your petition has already been granted. We have filed your petition as a comment in the docket to be considered in future rulemaking action on this subject. Further, we interpret the words "The exterior face of each...lens" in paragraph S4.1.1.36(a) (2) to mean all portions of the lens face including the mounting flange which is a molded and indivisible part of the lens. Thus, no rulemaking is considered necessary to implement this item of your petition. Your request also included a suggestion that the minimum height of the lettering for the adjustment of the legs on the aimer adapter should be reduced from 0.25 inch to 4 mm. This is being addressed in pending rulemaking. Therefore, no further action is necessary at this time.

Sincerely,