ID: aiam0404

Dear Mr. Wuddel: This is in reply to your letter of July 7, 1971, to the Nationa Highway Safety Bureau (now the National Highway Traffic Safety Administration) concerning the requirements for sealed beam headlamp units.; The answers to your specific questions are as follows: >>>1. Sealed beam units must meet the photometric specifications in SA J579 at the design voltage at or below the maximum amperes specified in SAE J573.; 2. Tolerances are as follows: *Electrical power* - the maximum electrical power is the product, i watts, of the design voltage multiplied by the maximum amperes at design volts. There is no specified minimum electrical power.; *Maximum amperes* - There is no tolerance. Maximum amperes is th maximum specified in SAE J573.; *Design watts* - There is no tolerance. There is, however, a toleranc on the actual watts or electrical power as described above.; 3. & 4. The filament types and positions are illustrative of curren practice only. Any type or position may be used to meet the specifications of J579 and J573.; 5. All glass sealed beam units are not mandatory. There are n restrictions in Federal Motor Vehicle Safety Standard No. 108 or the SAE Standards on the number of pieces or the materials which are used to complete the assembled sealed beam unit as long as the specifications, including those in SAE J571, are met. Caution should be used, however, to ensure that a good and durable seal is obtained between the metal back, if used, and the other parts to optimize the useful service life of the sealed beam unit.<<<; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: nht92-5.24

DATE: July 9, 1992

FROM: Tilman (Tilghman) Spingler -- Robert Bosch GmbH

TO: Paul Jackson Rice -- Chief Counsel, NHTSA Administration

TITLE: Request for Interpretation

ATTACHMT: Attached to letter dated 8/3/92 from Paul J. Rice to Tilghman (Tilman) Spingler (A39; Std. 108)

TEXT:

FMVSS 108 requires for Replaceable Bulb Headlamps a vertical aim range of > +/- 4 degrees and a horizontal aim range of > +/- 2.3 degrees. Does this mean that a headlamp has to meet both ranges in addition, i.e. 2.5 degrees horizontal at a full range of 4 degrees vertical and vice-versa? Would it be possible to give me a "quick" answer by fax?

ID: nht71-2.48

DATE: 05/12/71

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

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 3 asking for confirmation of your understanding with Mr. Vinson of my staff that the "optical horn" lighting feature is not prohibited by paragraph S4.6(b) of Motor Vehicle Safety Standard No. 108.

Paragraph S4.6(b) which states in part that "means may be provided to flash headlamps . . . for signaling purposes" allows the use of an automatic device for headlamp flashing, and it follows that a non-automatic system, such as the "optical horn" incorporates, is also permissible.

ID: aiam2940

Dear Mr. Hall:This is in reply to your letter of December 21, 1978 asking about your responsibilities, as the manufacturer of a snow plow headlamp holder, under the National traffic and motor Vehicle Safety Act.; Under the Act a truck, with or without snow plow attachment, is 'motor vehicle' and the plow itself and any associated equipment is considered 'motor vehicle equipment' since it is an accessory or addition to a motor vehicle. But Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*, contains no requirements either for snow plow or accessory lighting, and your sealbeam holder therefore is not subject to regulation under the standard. However, as a manufacturer of 'motor vehicle equipment,' you are responsible for notification of purchasers and dealers, and remedy of any safety-related defects that may occur in your product. (Sec. 151 *et seq.* of the Act); As to 'what legal burden rests' with you as a 'manufacturer of th sealbeam holder as to the possible misuse' of your units once they leave your plant, we are uncertain what you mean by 'misuse.' If you mean that the holder is used in a way that you did not intend, then the question would appear to be one not answerable under Federal law. If the 'misuse' is attributable to a defect in the sealbeam holder, then the question would arise whether the defect is safety-related. If the answer is affirmative, then you would be subject to the notification and remedy provisions of the Act mentioned in the preceding paragraph.; We are forwarding a copy of your letter to the Federal Highwa Administration, Bureau of Motor Carrier Safety, for a reply to your question as to what Federal requirements must be met for use of your units 'on inter and intra state highways.'; Enclosed is a copy of Standard No. 108 as you requested, as well as copy of the Act.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: 15566.ztv

Mr. Junichi Yoshimoto
Deputy General Manager
Technical Administration Dept.
Koito Mfg. Co., Ltd.
Shizuoka Works
500, Kitawaki
Shimuzu-Shi, Shizuoka-Ken
Japan

Dear Mr. Yoshimoto:

This replies to your letter of July 7, 1997, asking for an interpretation of the headlighting requirements of Federal Motor Vehicle Safety Standard No. 108.

Your letter contains a drawing of a headlamp with two light sources, two separate lens and separate aimable reflectors and one housing. You have asked whether a pair of these units would be regarded as a two-lamp or a four-lamp headlighting system for purpose of compliance with the photometric requirements of Figure 15 (four lamps) or Figure 17 (two lamps).

Because the two light sources are in a single housing, we regard your drawing as showing a single headlamp. Therefore, a system consisting of two of these lamps would be a two-lamp system, required to comply with the photometric requirements of Figure 17.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.8/11/97

ID: 2876yy

Mr. Delbert N. Pier
Legislation and Compliance Coordinator
Hyundai America Technical Center, Inc.
5075 Venture Drive
Ann Arbor, MI 48108

Dear Mr. Pier:

This is in reply to your letter of February 11, l99l, asking for an interpretation of Motor Vehicle Safety Standard No. l08.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector) of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. l08.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:3/l4/9l

ID: nht91-2.31

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

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

TITLE: None

ATTACHMT: Attached to letter dated 2-11-91 from Delbert N. Pier to Paul Jackson Rice (OCC 5720)

TEXT:

This is in reply to your letter of February 11, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108.

ID: aiam0032

Dear Mr. Busby: In your letter of July 13, 1967, you requested clarification of severa issues relating to the location and size of turn signals as specified in the Initial Federal Motor Vehicle Safety Standards. Initial Standard No. 108, entitled, 'Lamps, reflective Devices, and Associated Equipment - Multipurpose Passenger Vehicles, Trucks, Trailers, and Buses, 80 or More Inches Wide Overall,' specifies that turn signal lamps shall conform to Class A of SAE Standard J588d. As stated in the enclosures to your letter, SAE Standard J588d specifies 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. This requirement of the SAE Standard is addressed to a single lamp with only one bulb. For a combination of lamps, such as that shown on the sketch enclosed with your letter, the intent of this requirement could be met if the optical center produced by the two bulbs is outside the 4-inch limit. The location of this optical center must be determined from laboratory test data, which was not presented in your letter.; *Proposed* Initial Standard No. 112, entitled, 'Lamps, Reflectiv Devices, and Associated Equipment - Passenger Cars, Motorcycles, and Multipurpose Passenger Vehicles, Trucks, Trailers, and Busses of less than 80 Inches Wide Overall,' would permit the use of Class B (SAE J588d) turn signal lamps until January 1, 1969. Under this provision, lamp No. 1 on your sketch would conform to the 4-inch spacing requirement. Combining lamp no. 1 and No. 2 to obtain a Class A Area would again result in the situation previously described with respect to location of the optical center.; Since your letter makes frequent reference to 'cars,' we assume tha you are primarily interested in the requirements of Standard No. 112. In this respect, we would caution you that the requirements specified therein are presently only proposed requirements, and are subject to change prior to issuance of the final standard.; Thank you for your interest in the motor vehicle safety standards. Sincerely yours, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service;

ID: 1982-1.11

TYPE: INTERPRETATION-NHTSA

DATE: 02/09/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: United Sidecar Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 9, 1981, asking several questions about Federal Motor Vehicle Safety Standard No. 108.

You have asked for a clarification of our position on pulsating headlamps and stoplamps commenting that several States have expressed a concern "that a light of variable intensity may be confused by the citizen as an emergency vehicle which is allowed to have flashing headlights."

As you have indicated, paragraph S4.6(a) of Standard No. 108 requires turn signal lamps, hazard warning signal lamps, and school bus warning lamps to flash when activated, while S4.6(b) requires all other lamps to be steady burning. By "steady burning," the standard means a light that is essentially unvarying in intensity. There is, however, an exception in S4.6(b) to the "steady burning" requirement. Means may be provided "to flash headlamps and side marker lamps for signalling purposes." Paragraph S3 of the standard defines "flash" as meaning "a cycle of activation and deactivation of a lamp by automatic means. . . ." In our view, a lamp whose intensity varies from a higher output to a lower output would not be "steady burning" or "flash" within the meaning of those terms and hence would be prohibited. But if complete deactivation occurs, then the lamp "flashes." Installation of flashing lamps under the S4.6(b) exception is not restricted to emergency vehicles. It is permissible under the standard for a motorcycle to have a device which gives the motorcyclist the option of causing the motorcycle headlamp to operate automatically through cycles of activation and deactivation instead of burning steadily.

On the other hand, stop lamps that either flash or are of variable intensity are not allowed by S4.6(b) of Standard No. 108 since they are not steady-burning while in use.

I hope this answers your questions.

SINCERELY,

United Sidecar Association, Inc.

September 9, 1981

Office of the Chief Counsel NHTSA

Gentlemen:

We are quite perplexed regarding the legality or otherwise of certain devices used in lighting circuits of motorcycles. Specifically, we refer to devices to flash or modulate or pulsate the light intensity, whether for headlights, or for stop lights.

As we understand FMVSS 108, all lights installed on a motor vehicle must be STEADY BURNING with the sole exception being turn signal lamps, hazard warning signal lamps, school bus warning lamps and various lamps used by police and emergency vehicles.

It is also our understanding that steady is equivalent to uniform, stable, not shaky, regular, continuous, uniform and constant. In other words, a steady light is one that does not flash, pulsate, or is otherwise discontinuous or variable in intensity.

Many devices are now offered for sale that cause the headlight to vary in intensity. Others are available to pulsate or blink the stop light. The purported purpose of these devices is to attract more attention to the light. And, if so, the user is alleged to be safer. However, several Departments of Public Safety have expressed a concern that a light of variable intensity may be confused by the citizen as an emergency vehicle which is allowed to have flashing headlights.

The citizen will not readily recognize the subtle difference between a pulsating headlight or a modulating headlight or a flashing headlight. When he sees a flashing headlight will he respond as if it were an emergency vehicle or as just another motorcycle?

AS we understand from verbal communications with NHTSA officials, a pulsating headlight is a steady light but a pulsating stop light is not a steady stop light.

This is indeed most perplexing and confusing.

If the pulsating headlight is steady, then it would not appear to require State legislation for its use. If it is not steady then it is prohibited under FMVSS 108. If the pulsating headlight is steady, then it can be used for any application. If not, it can be used for none.

We are anxious to promote the safety and well being of our members. However, we cannot and will not promote any device that appears to be illegal and in contravention to State or Federal regulations.

We urge, with utmost expediency, a full and complete definition of exactly what is and what is not a steady, burning light. Also, what type of devices, if any, have been approved by NHTSA and by the appropriate regulatory bodies for varying the intensity of the headlight and the stop light.

If a device that varies the intensity of the headlight at 3 to 5 Hz is legal, then is a device that varies the headlight at 0.75 to 1.5 Hz legal if some voltage is always applied to the light bulb? Also, what criteria is legal for variable intensity stoplights?

H. A. Kendall, Ph.D.

ID: aiam4354

Dear Mr. Roberts: This is in reply to your letter of June 9, 1987, with respect to a aftermarket motorcycle lamp that you wish to produce. You refer to the lamp as a 'motorcycle safety light' that would supplement other motorcycle lighting and 'would be a rear facing or all direction light with an amber colored lens that would flash'. You have asked if there are any restrictions or guidelines for such a lamp.; Your letter does not indicate the size, flash rate, or intensity of th light, nor whether you intend it so be installed by motorcycle dealers prior to the first sale, or available only for installation on motorcycles already in use. However, I can give you some general guidelines.; Federal Motor Vehicle Safety Standard No. 108, *Lamp, Reflectiv Devices, and Associated Equipment* contains the requirements that apply to motorcycles and must be met at the time of sale and delivery to their first owner. Generally, except as provided in the standard (*e.g* motorcycle headlamp modulating devices) all lamps must be steady burning in use. Your lamp, however, would flash, and therefore appears precluded as an item of original equipment. Further, vehicle equipment must not impair the effectiveness of lighting equipment required by the standard. Although in the absence of specifications of your lamp we cannot say whether it would impair the effectiveness of required motorcycle lighting equipment, we note that an(sic) rearward facing amber flashing lamp could create confusion with a rearward facing amber turn signal lamp.; As an aftermarket device intended for vehicles in use, your lamp i subject only to the Federal restriction that its installation by a dealer, distributor, or motor vehicle repair business shall not render inoperative in whole or in part other required lighting equipment. Should your device place an excessive drain on a motorcycle battery affecting the operability of other lighting equipment it could be viewed as violative of the Federal restriction. However, even if this question is answered in the negative, the question of the acceptability of the supplemental lamp is determined by the laws of the State in which the device is sold or used. We are unable to advise you on these laws, and suggest that you write American Association of Motor Vehicle Administrators, 1301 Connecticut Ave., N.W., Washington, D.C. 20016, for further information.; Sincerely, Erika Z. Jones, Chief Counsel