Interpretation ID: nht90-1.42

TYPE: INTERPRETATION-NHTSA

DATE: 02/13/90

FROM: RICH VAN IDERSTINE

TO: TAYLOR

TITLE: INCOMING REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 3-23-90 TO TILMAN SPINGLER, ROBERT BOSCH GMBH, FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; INTERP. STD. 108]; ALSO ATTACHED TO TELEFAX DATED 1/30/90 TO RICHARD VAN IDERSTINE FROM T. SPINGLER.

TEXT: Attached is a fax from Bosch that I received last Friday through some circuitous internal NHTSA mail routing.

To help in your preparation of a letter (fax?) of interpretation, I offer the following:

Question 1. "To turn the adjusting screws of a HB2-headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?"

S7.7.2 permits protective covers removable without the use of tools, for meeting the need for accessibility of mechanisms that allow aim inspection and adjustment for both vertical and horizontal aim.

Question 2. "A combination of HB2-headlight (low- + High-beam) and auxiliary driving beam in one unit shall be equipped with only vertical adjusting screws for the driving beam. The beam pattern will be so wide that even bulbs with extreme tolerances w ill allow to meet all photometer requirements without horizontal adjustment. Will this be legal?"

Again, S7.7.2 states that each headlamp shall be installed with a mounting and aiming mechanism that allows aim inspection and adjustment of both vertical and horizontal aim. . . . Thus, the headlamp in question must have both horizontal and vertical aiming screws for that part of the headlamp which provides the lower and upper beam. For that part of the same headlamp which is a driving beam and thus not regulated by Standard No. 108, NHTSA does not care how that is made adjustable for aiming purpo ses. Therefore the headlamp as described would not be legal if it did not have horizontal aiming screws or the equivalent mechanism for that part which provides the lower and upper beam.

Question 3. "When will the 9007 bulb be legal? Date of final rule?"

The next action on the HB5 (industry trade no. 9007) is expected in May 1990, as was stated in the January 18, 1990 NHTSA-Industry Public Meeting.

Attachment

P.S. Could you have your secretary send a copy of the latest 108 over the WANG System to me?

Thanks, (Illegible Word)