Interpretation ID: 3132o
Manager, Safety Engineering
Mazda (North America), Inc.
Research & Development Center
1203 Woodbridge Avenue
Ann Arbor, MI 48105
Dear Mr. Kadoya:
This is in reply to your letters of July 14, l988, with respect to an interpretation of Motor Vehicle Safety Standard No. 108 and a request for confidential treatment of it. We understand that you orally withdrew this request during a telephone conversation with this Office on August 23, l988.
You have asked whether Standard No. l08 permits the use of replaceable bulb headlamps with adjustable reflectors, or the use of such lamps as fog and/or cornering lamps. Although Standard No. l08 defines a replaceable bulb headlamp as one with a bonded lens-reflector assembly, this definition does not preclude a design with an adjustable reflector, as the bond may be applied to a portion of the reflector assembly that is not adjustable. However, a headlamp with an adjustable reflector must be designed to conform with all applicable photometric requirements with the reflector in all positions in which it may be adjusted.
As for its use as a fog or cornering lamp, you are correct that it is acceptable provided that it does not impair the effectiveness of the lighting equipment required by Standard No. l08. Whether the device impairs the effectiveness is determined by the vehicle manufacturer before it certifies compliance with all applicable Federal motor vehicle safety standards. The decision, however, may be questioned by this agency if it appears erroneous.
I hope that this answers your questions.
Sincerely,
Erika Z. Jones Chief Counsel
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