Interpretation ID: nht90-3.96

TYPE: Interpretation-NHTSA

DATE: September 12, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: M. Guy Dorleans -- Manager, Regulatory Affairs Department Division Elairage-France, Valeo

TITLE: None

ATTACHMT: Attached to letter dated 7-19-90 from G. Dorleans to P.J. Rice (OCC 503); Also attached to a study entitled Aiming Concept for Headlamps, Solution 3; Also attached to drawing (graphics omitted)

TEXT:

This is in further reply to the letter you and Monsieur Ravier sent on July 19, 1990, with respect to the acceptability of "Aiming concept for headlamps. Solution 3" under Motor Vehicle Safety Standard No. 108. Ms. DeMeter informed Monsieur Ravier on A ugust 8, 1990, that your request for confidentiality of the drawing enclosed had been granted. You did not make a similar request for treatment of your two-page description of Solution 3, and accordingly we are incorporating it by reference in this lett er, and it will be made a part of all public copies of this interpretation.

Section S7.7.5 of Standard No. 108 states that "When a headlamp system is installed on a motor vehicle, it shall be aimable with either an externally applied aiming device, or on-vehicle headlighting aiming devices installed by the vehicle manufacturer." Section S7.7.5.1 sets forth the requirements for external aiming, and section S7.7.5.2 those for on-vehicle aiming. Solution 3 features a lamp which has three aiming pads on the lens, for use with a mechanical aiming device in accordance with SAE requ irements. However, the lamp also has a movable reflector and various horizontal and vertical aim features that appear to be related to on-vehicle aiming. The horizontal and vertical aiming screws, while having markings of angles similar to that require d for on-vehicle aiming devices, are used exclusively in conjunction with the SAE mechanical aiming device. Therefore, we would consider Solution 3 to be a lamp system intended to be aimable by external means, as provided in section S7.7.5.1.

Since this system departs from the procedure normally used with the SAE mechanical aimers, we commend you in your intent to provide appropriate aiming instructions for such headlighting systems with the vehicles operator's manual, even though it is not r equired by Standard No. 108.

I hope that this is responsive to your question.