Interpretation ID: nht91-1.47

DATE: February 20, 1991

FROM: Saburo Inui -- Corporate Manager, Toyota Motor Corporate Services of North America, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Interpretation of FMVSS No. 108 -- High Intensity Discharge Headlamps

ATTACHMT: Attached to letter dated 3-25-91 from Paul Jackson Rice to Saburo Inui (A37; Std. 108)

TEXT:

This is a request for an interpretation of Federal Motor Vehicle Safety Standard ("FMVSS") No. 108 concerning High Intensity Discharge Headlamps ("HID").

Although in the February 8, 1990 amendment of FMVSS 108 (Docket No. 85-15; Notice 12) NHTSA clarified that HID headlamps are not excluded as integral beam headlamp systems, Toyota has some additional concerns.

1. Configuration:

S5.4, Equipment combinations, provides that "(t)wo or more lamps . . . may be combined if the requirements for each lamp . . . are met . . . ."

S4. Definitions, defines "Integral Beam Headlamp" as "a headlamp comprising an integral and indivisible optical assembly including lens, reflector, and light source, that is neither a standardized sealed beam headlamp designed to conform to paragraph S7.3 nor a replaceable bulb headlamp designed to conform to paragraph S7.5."

The Toyota HID headlamp comprises "an integral and indivisible optical assembly including lens, reflector, and light source" (see Figure 1), and although it contains replaceable bulbs (the inexpensive parking lamp and turn signal lamp bulbs are replaceable), it is not a "replaceable bulb headlamp DESIGNED TO CONFORM TO PARAGRAPH S7.5." (Emphasis added.)

Therefore, the Toyota combination HID headlamp system is not precluded by FMVSS 108, provided of course that all other applicable requirements are met. (To suggest otherwise would require the replacement of the entire assembly at substantial cost should only an inexpensive parking lamp or turn signal bulb fail.)

2. Hard-wire connection:

Due to limited space for accommodation of HID headlamps in the vehicle, it may not be practicable to integrate the ballast (starter and converter) into the headlamp enclosure.

In one case, the ballast would be divided into two units -- a starter and a converter -- permanently connected using hard-wire (electrical wire resistant to cutting and abrasion) as depicted in Figure 2.

Such a headlamp configuration would still constitute an integral beam headlamp system, we believe.

3. Hard-wire and connector:

In some cases, vehicle body construction may dictate that the ballast units be installed in the vehicle separately, and then permanently connected electrically.

In such cases, electrical connectors would have to be provided between the starter and the converter as depicted in Figure 3.

To be considered an integral beam headlamp system under FMVSS 108, we believe all three of the following conditions would have to be met by such an HID headlamp:

(1) Connectors would be permanently coupled at vehicle assembly.

(2) Only complete headlamp systems would be available as replacement parts, and not individual parts, such as a starter or converter.

(3) Connectors supplied with replacement parts for use by repair shops and garages would be designed to be fastened permanently after coupling (they would self-destruct if they were subsequently forced apart), and would be described in the shop manuals.

With these three conditions, headlamp replacement would always mean replacement of the entire headlamp system, resulting in consistency with conventional integral beam headlamp systems.

This "hard wire" or "hard wire and self-destruct connector" arrangement is indispensable to enable us to install our HID headlamp system into our U.S. vehicles. We therefore seek NHTSA's confirmation of our interpretations concerning the use of these headlamp systems.

Thank you for your prompt consideration of this matter.

Should you have any questions, please contact Mr. Manabu Morisaka of my staff at (202) 775-1707.

Attachments

Figures 1, 2, and 3 (Graphics omitted)