Interpretation ID: 1983-2.45

TYPE: INTERPRETATION-NHTSA

DATE: 08/17/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield, MI 48075

Dear Mr. Nakaya:

This is in response to your letter of July 8 1983 asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Section S4.2 of SAE Standard J588e Turn Signal Lamps establishes a minimum distance of 4 inches from the optical axis (filament center) of the front turn signal to the inside diameter of the retaining ring of the headlamp providing the lower beam. You believe that it is not necessary to have a retaining ring on a semi-sealed headlamp and you have asked whether you may substitute the edge of the reflector (as shown on your drawing) to measure the dimension covered by S4.2 of J588e.

The point depicted on your drawing appears to be the inner edge of the reflector, rather than the extreme edge; nevertheless, the "reflector edge" you have indicated is the approximate location of a retaining ring on a fully sealed headlamp, and is therefore acceptable as a measuring point under Standard No. 108.

Sincerely,

Frank Berndt Chief Counsel

July 8, 1983

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W.

Washington; D.C. 20590

Dear Mr. Berndt:

Mazda requests interpretation regarding the amendment to FMVSS No.108 which allows the use of semi-sealed headlamps (Docket No. 81-11; Notice 3, 48 F.R. 24690).

Section 4.2 of SAE Standard J588e states that, "The optical axis (filament center) of the front turn signal shall be at least 4 in. from the inside diameter of the retaining ring of the headlamp unit providing the lower beam." However, it is not necessary to have a retaining ring on a semi-sealed headlamp. We, therefore, believe that it is appropriate to use the edge of the reflector, instead of the inside diameter of the retaining ring, to measure the dimension described in Section 4.2 of SAE Standard J588e (See attached sketch).

We would appreciate your interpretation of this matter as soon as possible.

Very truly yours, H. Nakaya Manager

HN/ab

cc: Att.

FIGURE 1: SEMI-SEALED HEADLAMP (PLAN VIEW SECTION) GRAPH INSERTED HERE REFLECTOR EDGE