Interpretation ID: nht87-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Department Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of March 4, 1987, with reference to aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also fu nctions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp "is acceptable in the U.S.A."

Federal Motor Vehicle Safety Standard No. 108 contains no requirements for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not create a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirements for f og lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met; we can only advise you that it does not appear prohibited by Federal law.

The American Association of Motor Vehicle Administrators (AAMVA), 1201 Connecticut Avenue, N.W., Washington; D.C., 20036 may be able to advise you as to state laws relevant to your design.

Sincerely,

Erika Z. Jones Chief Counsel

March 4, 1987

Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Aiming adjustment of Front fog lamps

We are now developing a new fog lamp, which has a common lens and housing with a replaceable bulb headlamp. (See attached drawing.)

Since the portion of housing also functions as a reflector, this new fog lamp moves simultaneously with headlamp in aiming adjustment.

This fog lamp is designed to satisfy the requirements of SAE Standard J583. So it will not impair the effectiveness of the headlamp, or rather, it will promote the function of headlamp. We Think this new fog lamp is acceptable in the U.S.A.

Please give your advice whether our understanding is right or not.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada Manager, Automotive Lighting Engineering Control Dept.

SEE ATTACHMENT