Interpretation ID: nht88-3.18

TYPE: INTERPRETATION-NHTSA

DATE: 08/26/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: MAMORU ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING HOMOLOGATION SECT. STANLEY ELECTRIC CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 07/07/88 TO ERIKA Z JONES FROM MAMORU ARISAKA, OCC - 2268

TEXT: Dear Mr. Arisaka:

This is in reply to your letter of July 7, 1988, with respect to a motorcycle lighting device called the "rolling headlamp." The headlamp is designed to have its vertical plane always perpendicular to the ground regardless of the inclination of the motor cycle. You have asked whether such a device is legally permissible.

Motor Vehicle Safety Standard No. 108 does not prohibit alteration of the mounting angle of a headlamp. Although paragraph S4.3.1 requires each lamp to "be securely mounted on a rigid part of the vehicle," your lamp appears to be "securely mounted" even if it is able to rotate.

I hope this answers your question.

Sincerely,