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Interpretation ID: nht92-7.48

DATE: April 6, 1992

FROM: Gonshiro Miyoshi -- Manager, Design Administration Dept., Technical Division Ichikoh Industries, Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Our Reference LO4-11

ATTACHMT: Attached to letter dated 5/8/92 from Paul J. Rice to Gonshiro Miyoshi (A39; Std. 108)

TEXT:

This letter is in regards to the interpretation of headlamp arrangement in FMVSS No. 108.

We would like to know your opinion regarding the below mentioned arrangement of headlamp system consisting of two lamps, each containing two light sources.

Is it permissible to have the bulb center of the lower beam lower than that of the upper beam (maximum height difference is 10mm) if they are arranged horizontally?

Kindly let us know your opinion concerning the above matter.