Interpretation ID: aiam4283
Manager
Automotive Lighting
Engineering Control Department
Stanley Electric Co. Ltd.
2-9-13
Nakameguro
Meguro-ku
Tokyo 153
Japan;
Dear Mr. Chikada: This is in reply to your letter of August 4, 1986, with respect to new headlamp and aiming adaptor design. The lens of the headlamp will be titled 60 degrees from vertical. Although this is too extreme an angle for use of mechanical aimers for headlamps, you have developed an adaptor for use with the aimer whereby the new headlamp may be mechanically aimed. You have asked whether mechanical aim using the new adaptor is permissible.; Federal Motor Vehicle Safety Standard No. 108 does prescribe the type of aimers to be used with replaceable bulb headlamps, but not the adapters. As you have noted, the standard does require such headlamps to be capable of mechanical aim by incorporating on the lens face three pads which meet the requirements of the standard's Figure 4. You have informed us that your headlamp design complies with this requirement, and furthermore meets the photometric requirements of Standard No. 108.; However, there are some practical considerations that are important i you intend to market this headlamp. Although providing an aimer adaptor is not required by Standard 108, no adapters for your unique lamp have been provided to service facilities. The only adaptor which exist today are those designed to accommodate sealed beam headlamps, and replaceable bulb headlamps with lens angles up to 50 degree for smaller lamps and 40 degrees for large ones. Neither of these can accommodate the lamp you have proposed.; In summary, the standard does not appear to preclude use of your ne designs, and although not specifically required by the standard, an adaptor should be provided as original vehicle equipment since suitable adapters do not exist in the service community.; Subsequent to August 4, we received your request for confidentia treatment of the letter. We replied that it is our policy that substantive interpretations be made publicly available but informed you that we would be willing to delete all identifying references to you and your company. You replied that this was agreeable to you. However because this headlamp is the subject of SAE Technical paper 870064 *Development of MR (Multi- Reflector Headlamp)* and was discussed at SAE meetings in February 1987, Stanley has waived all considerations of confidentiality through its public disclosure of the matter. Consequently, this letter will be made publicly available.; Sincerely, Erika Z. Jones, Chief Counsel