Interpretation ID: nht89-3.16

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 13, 1989

FROM: BILL WALTZ -- WAGNER DIVISION, COOPER INDUSTRIES, INC.

TO: STEPHEN WOOD -- ACTING CHIEF COUNCIL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED APRIL 8, 1990 TO BILL WALTZ FROM STEPHEN P. WOOD; (A35; STD. 108)

TEXT:

Lectric Limited has asked Wagner to assemble some round glass headlights for them, designed to appear as closely as possible to those produced by Guide Lamp in the 1950's.

All markings and configurations on the original lamps are being reproduced and this creates a problem in complying with "108". The lamps they are interested in are 6012 (7"), 4001 (5 3/4" #1) and 4002 (5 3/4" #2). In accordance with the original marking they will have a "1" or "2" at the top of the lens, not the "2D1", "1C1" and "2C1" now required by NHTSA.

Secondly, the inscription DOT, indicating compliance with existing regulations, will be omitted, since this was obviously riot on the original lamps.

We are asking your permission for those deviations since the lamps will be made to today's photometric standards and will be distributed on a limited basis through antique part dealers. The lamps will be subjected to all the tests currently required of the round headlights.

If there is any problem with this production, please let me know, so that we can try to worK out a solution satisfactory to all parties involved.