Interpretation ID: nht90-2.72

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 3, 1990

FROM: MARGRET SCHMOCK -- ROBERT BOSCH GMBH

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

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO MARGARET SCHMOCK FROM STEPHEN P. WOOD; (A35; VSA 103(d)) TEXT:

Could you please be so kind and answer me some questions about the FVMSS 108 and the CAC Title 13, Article 9.

The amended FMVSS 108 says: S7.7.3 When a headlamp system is tested in a laboratory, the range of its vertical aim shall not be less than +/- 4 degrees ... S7.7.4 When a headlamp system is tested in a laboratory, the range of its horizontal aim shall not be less than +/- 2.5 degrees ... CAC says: The range of adjustment from the specified aim the lamp shall be at least +/- 4 degrees in both the vertical and horizontal directions. So my questions are: Does this mean that our headlamps still must have an adjustment range of +/- 4 degrees in horizontal direction, although the FMVSS 108 has been changed? Is it possible that the CAC meanwhile has been amended according to the FMVSS 108? Is it true that the CAC doesn't differ between auxiliary lamps and headlamps (in opposite to the FMVSS 108 that is only valid for headlamps)? Thanking you very much in advance for your actions.