Interpretation ID: 1984-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Pekka Suuronen -- Hella Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MR. Pekka Suuronen Hella, Inc. P.O. Box 1064 Cranford, NJ 07016

This is in response to your letter of November 30, 1983, clarifying your earlier requests for an interpretation of Standard No. 108. You have asked whether replaceable bulb headlamps may be manufactured in sizes identical to the current sizes for sealed beam headlamps, provided that they meet Stardard No. 108 in all other respects.

The replaceable bulb headlamp amendment was adopted with the intent of allowing Vehicle manufacturers greater flexibility in the front end design in order to improve aerodynamics. The amendment allows an original equipment two-lamp system of no specified dimensions, and replacement lamps for these systems. It was not directed towards replacement lamps for existing headlamp systems. However, because no exterior dimensions for headlamps are specified by the amendment, replaceable bulb headlamps intended for use in a two-lamp system, with exterior dimension of sealed beam round or rectangular two-headlamp systems, would be permissible assuming that they meet all other requirements of Standard No. 108, including providing one of the two aiming pad locations specified for replaceable bulb headlamps. However, until Standard No. 108 is amended to allow a four-lamp replaceable bulb headlamp system, these lamps are precluded from being manufactured to replace today's sealed beam round and rectangular sealed beem headlamps used in four-lamp systems.

I hope this provides the clarification you seek.

Sincerely,

Frank Berndt Chief Counsel

November 30, 1983

NHTSA 400 Seventh St. NW Washington, DC 20590 ATTN: Frank Berndt, Chief Counsel

Dear Mr. Berndt,

Thank you for your letter of November 17, 1983, reference "NOA-30". I would like to clarify my question. I realize there is only one "legal" replaceable headlamp bulb which I call "Ford bulb", lacking a more official nomenclature.

By " six standard sizes" I mean headlamps, not bulbs. In other words, headlamps that would replace current six types 2D1, 1C1, 2C1, 1A1, 2A1, and 2B1. However, these proposed lamps would have a replaceable "Ford bulb" and a sealing just like in the Ford headlamp. In the case if Type 1 headlamp, only the high beam filament would be connected. The photometrics would meet the current SAE standards, the lamp would be mechanically rimable and the new proposed lamps would comply to all other applicable safety standards, as well.

My question is, would these kinds of headlamps be highway legal?

Please note that Racemark no longer is the importer of Hella. Please correspond to the address shown on the letterhead.

Sincerely,

PEKKA SUURONEN PS / lP