Interpretation ID: aiam3734
Manager
Technical Administration Department
Koito Manufacturing Co.
Ltd.
Shizuoka Works
500
Kitawaki
Shimuzu-shi
Shizuoka-ken
424
Japan;
Dear Mr. Iwase: This is in reply to your letter of June 22, 1983, to Mr. Medlin of thi agency asking for an interpretation of the recent amendment to Motor Vehicle Safety Standard No. 108 allowing use of replaceable bulb headlamp systems.; Regarding plastic lens materials, you have asked the limits o luminance transmittance loss and presence of haze after outdoor exposure test. These values are those specified by the referenced SAE standard, J576c.; You have also asked whether an accelerated weathering test i acceptable, such as ASTM E 838. Our reply is that you are free to conduct any accelerated weathering test you deem appropriate to support certification of compliance to Standard No. 108. We have not adopted any such test and will perform our compliance tests according to the 3-year test in SAE J576c.; Regarding the structural configuration of headlamps, you have aske about methods that may be acceptable to joining the lens and reflector, such as glue or welding. Standard No. 108 specifies no method for joining components, and any method is acceptable which results in an indivisible lens-reflector unit. Use of clips to supplement glue is permissible but use of clips alone would not result in an indivisible lens-reflector assembly. There is no objection to use of an additional rubber boot behind the reflector and bulb in the manner depicted in your letter. Drain holes, etc. may be provided as long as the headlamp complies with all the requirements of Standard No. 108. We shall publish in the near future a clearer indication of the headlamp terminal arrangement, as well as the dimensional specifications of the connector to the terminals of the bulb socket. We do not understand your request about the specific dimension and shape of each terminal 'blade' as the length, thickness, and width are already specified in the amendment (Figure 3-3). You have asked also whether the wattage values of 65 for the upper beam and 45 for the lower beam are maximum or nominal values. These values are maximum values.; Finally, concerning patent matters, you have asked whether certai aspects of the bulb and socket assembly are the subjects of patent claims. Ford has indicated in a letter of March 2, 1983, that, 'To facilitate compliance with the standard by all who wish to make or use replaceable bulb headlamps or their components, Ford Motor Company offers to grant royalty-free non-exclusive licenses to all manufacturers of motor vehicles, headlamps, or headlamp components that request such licenses, under U.S. patents and U.S. patent applications which claim these inventions to the extent that their use is needed to employ the proposed optional headlamp system.' If you have further questions on this issue you should write to Ford Motor Company.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel