Interpretation ID: nht89-2.99

TYPE: INTERPRETATION-NHTSA

DATE: 09/14/89

FROM: S. WATANABE -- MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC COMPANY

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL U.S. DOT, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/89 FROM STEPHEN P. WOOD -- NHTSA TO JOHN K. MOODY -- MOODY AND MOODY ENTERPRISES; REDBOOK A34; STANDARD 108; LETTER DATED 08/30/89 FROM JOHN K. MOODY -- MOODY AND MOODY ENTERPRISES TO TAYLOR VINSON -- NHTSA; OCC 3 905

TEXT: Dear Sir,

We are now developing a Head Lamp equipped with VHAD, whose structure is shown in the attached drawing. Please give us the advice to the following questions about this Head Lamp.

1) Does a VHAD without a function which compensates the deviation of floor slope satisfy FMVSS No. 108 S7.7.5.2.(a).(1).(V)?

2) This Head Lamp is designed to be aimed vertically by means of observing only one spirit level placed on the movable reflector, as shown in the drawing. Does this structure of VHAD satisfy FMVSS No. 108 S7.7.5.2.(a).(1).(V)?

Any information that might be of our interest when designing the Head Lamp with VHAD, as well as the answers to the above questions, would be highly appreciated.

Yours faithfully,