Interpretation ID: 1984-4.9
TYPE: INTERPRETATION-NHTSA
DATE: 12/19/84
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: American Honda Motor Co., Inc. -- Brian Gill, Manager, Certification Dept.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Brian Gill Manager, Certification Department American Honda Motor Co., Inc. P.O. Box 50 Gardena, California 90247
This is in reply to your letters of October 8 and 26, 1984, with respect to a proposed motorcycle headlighting system. In this design, two bulbs, each with its own reflector, are combined in a single housing. You have informed us that both bulbs are illuminated when the headlamp is on and together provide "the proper photometric output for low and high beams." Further, each reflector is adjustable individually, horizontally and vertically. The lamp has been designed to comply with the requirements of SAE J584.
Your contemplated design is acceptable for motorcycles; SAE J584 refers to a "light source or sources" ( see "At-Focus Tests") . However, a two-bulb design in a single housing would have to be designed to meet J584's requirements for a single headlamp including maximum output of 75,000 cd. Further, Standard No. 108 permits independently aimable reflectors, or aim by moving the entire assembly whichever you prefer. All that is required is that the unit meet SAE J566 Headlamp Mountings, January 1960.
I hope that this answers your questions.
Sincerely, Frank Berndt Chief Counsel
October 26, 1984
Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street, S.W. Washington, D. C. 20590
Dear Sir:
This is in regard to the motorcycle headlight system which I described in my letter of October 8th.
Since that time I have met with Mr. Richard Van Iderstine, Safety Standards Engineer in the Office of Vehicle Safety Standards to discuss this headlight. The following information is provided as a result of that discussion:
1. The device in question is a single motorcycle headlight.
2. The headlight complies with SAE J584, April 1984 as specified in Federal Motor Vehicle Safety Stadard (FMVSS) number 108.
We would appreciate your cooperation in reviewing this material and your confirmation that the headlight complies with FMVSS 108 requirements. Please call me at (213) 327-8280, extension 2198 if you have any questions or comments.
Yours truly,
AMERICAN HONDA MOTOR CO. , INC.
Brian Gill Manager Certification Department BG/jb
October 8, 1984
Office of the General Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Department of Trasportation 400 Seventh Street, S.W. Washington, D.C. 20591
Dear Sir:
Enclosed are drawings of a headlight system designed for use on certain 1985 model year motorcycles. We would like to confirm that this design complies with the requirements of FMVSS 108.
Both bulbs are illuminated ay time that the headlight is switched on and together provide the proper photometric output for low and high beams. Each reflector is adjustable individually both horizontally and vertically.
Mr. Medlin of the Crash Avoidance Division of NHTSA told me on October 5th that you are currently considering a similar device but with some significant differences, and that I should bring our motorcycle headlight system to your attention as soon as possible.
I will try to contact Mr. Vincent by telephone on October 10th to discuss this matter further.
Yours truly,
AMERICAN HONDA MOTOR., INC.
Brian Gill Manager Certification Department BG:lw Enclosure Insert,two charts