Interpretation ID: 1984y

With respect to the interpretation furnished you on July 21, l989, you have requested the following clarification in your letter of the 28th: that the provisions of paragraph S7.4 of Standard No. l08 that relate to filament usage do not apply to the headlamp system previously described. You have also confirmed that this system is designed to conform to all other requirements of Standard No. l08 "including photometric, special wiring, mechanical aim, environmental and marking requirements.

Paragraph S7.4 describes a variety of headlighting systems which come under the heading of "integral beam systems." The beams in these systems will be produced by "beam contributors" (S7.4(a)(3)), headlamps containing "two light sources" (S7.4(b)), or headlamps containing "a single filament" (S7.4(c)). The arc tubes in the system you describe would appear to be "beam contributors" within the meaning of S7.4, and the filament language of paragraph S7.4 would not apply to this particular type of integral beam headlighting system.

We will honor your continuing request that your name and those of your firm and client be deleted from the copy made publicly available.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d:8/l7/89