Interpretation ID: 1983-3.21

TYPE: INTERPRETATION-NHTSA

DATE: 11/18/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Hueck & Co.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. I. A. Wuddel Westfalische Metall Industrie KG Hueck & Co. Postfach 28 40 4780 Lippstadt Germany

Dear Mr. Wuddel:

This is in reply to your letter of September 9, 1983, to August Burgett of this agency. With reference to the recent amendment to Motor Vehicle Safety Standard No. 108 permitting semi-sealed replaceable bulb headlamp systems, you have asked whether a headlamp assembly would be allowed which also incorporated a European H1 or H2 bulb, "for an auxiliary driving beam or a front fog lamp, as our customer requests it."

It is our understanding that the H1 bulbs are commonly used in European lamps as the principal lighting source, and that H2 bulbs are used in high intensity supplemental front lamps. Therefore, use of one of these bulbs in a replaceable bulb headlamp would create, in effect, a system of four headlamps. The agency recently denied a petition by Volkswagen for a four-lamp system at this time using the standardized replaceable light source (copy enclosed), because of unresolved issues. We therefore are currently unable to allow a system such as you propose with the H1 or H2 bulb in a common housing with the standardized replaceable light source, creating in effect a four-lamp headlamp system. Further, paragraph S4.1.3 of Standard No. 108, prohibits the installation of additional lighting equipment which impairs the effectiveness of lighting equipment required by Standard No. 108, and there is the distinct possibility that this could occur through incorporation of the H1 and H2 bulbs.

Use of the H1 and H2 bulbs in separate and independent units for driving or fog lamps remains permissible, subject to regulation by the individual American States, as these items are not covered by Standard No. 108.

You may be interested to know that Volkswagen of America has recently petitioned us for rulemaking that would allow use of the H4 bulb instead of the standardized replaceable light source in replaceable bulb headlamp systems. A decision is pending whether to grant this petition.

Sincerely,

Frank Berndt Chief Counsel Enclosure

Mr. A. Burgett Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. USA - Washington, D.C. 20590

BV Wu/Mei 7509 09-09-1983

Dear Sir,

Since optional headlighting systems are allowed according to FMVSS No. 108 (Docket No. 81-11, Notice 3) on certain promises, we intend to develop a semi-sealed headlamp assembly with two adjacent reflectors, moulded as one part, and a lens covering both reflector sections. The lens and the dual reflector would be sealed. The outward reflector would be equipped with a standardized replaceable bulb (Ford bulb) for the required upper and lower beam, and the inward reflector would be equipped with a european replaceable bulb type "H1" or "H2" for an auxiliary driving beam or a front fog lamp, as our customer requests it. The optical axis of the system would be parallel. On surface of the lens area for upper and lower beam there would be three aiming pads by which a common aiming adjustment of both the upper/lower beam and the auxiliary driving or fog lamp beam could be carried out.

We would like to learn whether such a headlamp assembly would be allowed or it is required that the aiming adjustment must be possible for each reflector.

Please find attached sketch.

Yours sincerely

Westfalische Metall Industrie Kommanditgesellschaft Hueck & Co. i. A. Wuddel Headlamp Assembly

*Insert diagram here