Interpretation ID: nht91-1.38

DATE: February 11, 1991

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

TO: Paul Jackson Rice -- Chief Council, NHTSA

TITLE: Re FMVSS Number 108, Lamps, Reflective Devices, and Associated Equipment

ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to Delbert N. Pier (A37; Std. 108)

TEXT:

Hyundai requests assistance with an interpretation regarding Federal Motor Vehicle Safety Standard, Number 108 (lamps, reflective devices, and associated equipment).

In regards to the interchangeability of headlamp bulbs, the procedure (571.108) requires that the terminals must be perpendicular to the base and parallel within plus or minus 1.5 degrees.

Hyundai would like an interpretation on whether the bulb fixture can be rotated approximately 11 degrees, as shown in the attachment, view X. This will not change the terminal logistics by the rotation of the bulb fixture. This rotation will not change the constants, (attachment, view Y, from 49 CFR) or the relationship of the terminals to the constants.

Hyundai is requesting an interpretation for a future production vehicle and needs a prompt answer. Thank you for your assistance in this matter. Should further clarification be required, feel free to contact me at the telephone number listed above.

Attachment 1

S571.108 49 CFR Ch. V (10-1-89) Interchangeability Drawing Headlamp Bulb Assembly (Text and graphics omitted)