Interpretation ID: 19623.ztv

Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

Dear Mr. Suzuki:

This is in reply to your letter concerning the testing of reflectors of replaceable lens headlamps for chemical and corrosion resistance. I apologize for the delay in our response.

Under the test procedure established by S8.10.1(c), after test fluids are applied to headlamp reflectors, the reflectors "shall be wiped clean with a soft cotton cloth . . . ." You remark that the force applied to the reflector during cleaning is not specified, noting that if Stanley wipes the reflector "so gently that the surface would not be damaged, the headlamp will meet the requirements prescribed in S7.4(h)(2)," but, "on the other hand, if we wipe the reflector without any carefulness, the surface might be damaged." In your opinion, this means that "some kind of attention is needed to meet the requirement of S7.4(h)(2)." You ask "if such kind of attention is permitted under S8.10.1(c)."

S5.8.11 of Standard No. 108 requires that a replacement lens for a replaceable lens headlamp must be provided with a replacement seal in a package "that includes instructions for the removal and replacement of the lens, the cleaning of the reflector, and the sealing of the replacement lens to the reflector assembly." Although you reference only the chemical resistance test of S8.10.1(c), we note that the corrosion test contains a specific requirement that "the reflector shall be cleaned according to the instructions supplied with the headlamp manufacturer's replacement lens" (S8.10.2(b)). The instructions for the cleaning of the reflector may specify the force recommended to be applied for this operation.

If the instructions do not specify the force needed to wipe the reflector clean, we would interpret the test procedure as encompassing the range of force levels that technicians would reasonably employ to perform the required task. Thus, in a compliance test where instructions are silent as to the force to be used, no special care would be taken to use the minimum possible force, nor would the technician deliberately use excessive force.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/29/99