Interpretation ID: 1984-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 05/21/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Hella North America Inc. -- Walter A. Genthe

TITLE: FMVSS INTERPRETATION

TEXT:

January 23, 1984

Dear Mr. Berndt:

Westfaelische Metall Industrie KG is currently designing headlamps for several automobile manufacturers.

These headlamps are designed to comply with Safety Standards 108 as amended by Docket 81-11 (latest issue: Notice 7).

Preliminary requests by our customers mandate an inclusion of parking/front position lamps and/or turn signal lamps and/or side marker lamps in the overall headlamp design.

A standard U.S. light bulb, meeting FMVSS 108 and/or applicable SAE recommended practices, will be used for these respective functions.

We intend to incorporate these functions into the headlamp compartment, retaining the bulb in question by means of a sealed attachment, similar to the one used in the C6 capsule installation.

No degradation of the system will result, since both functions are contained in one sealed compartment, covered by one common lens. No impairment of the effectiveness of the headlamp function is anticipated, nor will the headlamp impair the function of the parking/position/side marker lamp.

All photometric and environmental specifications for such lamps will be met and no component will be used which is outside the scope of FMVSS 108.

To clarify our intent, a sketch showing the principal design has been enclosed.

We are requesting a statement concerning the agency's opinion in this matter; specifically, as it concerns the legality of the proposed system, whole or in part, and solicit any suggestions as to necessary changes should the system not be in compliance with FMVSS 108, as amended by Docket 81-11.

This matter is of considerable urgency, because of design and manufacturing lead times.

A reply at yyor early convenience coud therefore be appreciated.

Very truly yours,

HELLA NORTH AMERICA INC.

Walter A. Genthe President

WAG/1h

Encls.

cc: Dr. Ernst, K 1 Mr. Westermann, K 1 Mr. Fikus, AF

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MAY 21, 1984

Mr. Walter A. Genthe President Hello North America, Inc. P.O. Box 499 Flora, Illinois 62839

Dear Mr. Genthe:

This is in reply to your letter of January 23, 1984, with respect to the inclusion of other lighting functions in a replaceable bulb headlamp compartment. These functions could include parking lamps, turn signal lamps, or side marker lamps. The bulb used would meet Standard No. 108/SAE specifications for the function chosen and they would be incorporated into the compartment bya a "sealed attachment." You represent that there will be no impairment of any function, and that the overall assembly will meet all photometric and environmental specifications. You have asked whether such a combination assembly is permissible under Standard No. 108.

The agency interprets Standard No. 108's specifications for replaceable bulb headlamps as allowing only one bulb in a lamp assembly to be used for headlighting purposes. It is silent as to whether additional bulbs may be used to provide other lighting functions. This means that such a bulb is permitted.

Obviously the inclusion of a second bulb can affect the characteristics of the assembly, whether through heat build up, the introduction of contaminants through the junction of the bulb and assembly, etc. These problems would appear to be minimized under the assumptions set forth in your letter. We believe therefore that, under these conditions, an auxiliary bulb could be included in the headlighting compartment, provided that the assembly meets all applicable requirements of Standard No. 108 for each function. Problems that may develop in service would be subject to the safety related defects authority of the National Traffic and Motor Vehicle Safety Act.

If Hella proceeds with a multi-bulb, design, we would like to request that it share with us the types of tests it will be developing which it deems necessary to insure adequate safety performance, so that our knowledge of state of the art lamp technology may be broadened.

Sincerely,

Frank Berndt Chief Counsel

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