Interpretation ID: aiam4843
Inc. 5075 Venture Drive Ann Arbor
MI 48108;
Dear Mr. Pier: This is in reply to your letter of February 11, l99l asking for an interpretation of Motor Vehicle Safety Standard No. 108. With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked 'whether the bulb fixture can be rotated approximately 11 degrees', and have informed us that this will not change the 'constants . . . or the relationship of the terminals to the constants.' Standard No. 108 does not specify the orientation of replaceable light sources in headlamps, the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector) of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108. Sincerely, Paul Jackson Rice Chief Counsel;