Interpretation ID: aiam3901

Mr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada
Manager
Automotive Lighting
Engineering Control Dept.
Stanley Electric Co.
Ltd.
2-9-13
Nakameguro
Meguro-ku
Tokyo 153
Japan;

Dear Mr. Chikada: This is in reply to your letter of January 11, 1985, to Mr. Vinson o this office, asking for a clarification of certain terminology relating to the definition of a standardized replaceable light source in Motor Vehicle Safety Standard No. 108.; We are aware of the problem underlying your question, i.e., that th standard contemplates testing of the bulb with its base but the photometrics specified are appropriate for the capsule portion alone. Our Rulemaking staff is reviewing this issue. The agency will inform you of the results of that review. If appropriate, the issue will be addressed through an appropriate interpretation or amendment of the standard.; Sincerely, Frank Berndt, Chief Counsel