Interpretation ID: 17360.ztv

S. L. Law, Optical Design Manager
Magneti Marelli UK Ltd.
Lighting Division
Walkmill Lane, Cannock
Staffordshire WE11 3LP
England

Dear Mr. Law:

This is in reply to your fax of February 13, 1998, with reference to a proposed design for a tamperproof vehicle headlamp aiming device (VHAD).

Paragraph S7.8.5.2(c) requires, in pertinent part, that "each headlamp equipped with a VHAD that is manufactured for use on motor vehicles manufactured on or after September 1, 1998, shall be manufactured with its calibration permanently fixed by its manufacturer." General Motors seeks assurance from Magneti Marelli, therefore, that the VHAD on a headlamp it intends buying from the company is sufficiently tamperproof so that the calibration can be regarded as permanently fixed.

Your intent is to prevent the removal of the VHAD covering window, thus denying access to the adjustment screw. In the current design, the covering is applied with a clockwise rotation and is removable by a counterclockwise motion. In the proposed design, once the covering is applied with a clockwise rotation, it cannot be removed by a counterclockwise motion.

We have concluded that this design makes the VHAD sufficiently tamperproof that the calibration of the VHAD will comply with the requirement of S7.8.5.2(c) that it be permanently fixed.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.5/22/98