Interpretation ID: 1985-01.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/11/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHSTA

TO: Kazutoshi Kasagi -- Chief Inspector, International Trade and Industry Inspection Institute Ministry of International Trade and Industry (Japan)

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Kazutoshi Kasagi Chief Inspector Internationally Agreed Safety Division International Trade & Industry Inspection Institute Ministry of International Trade & Industry Japanese Government 15-1, 6 Chome Ginza Chuo-ku Tokyo, Japan

This is in reply to your letter of November 13, 1984, with respect to interpretations of the motorcycle headlighting requirements of Federal Motor Vehicle Safety Standard No. 108, and SAE J584.

You have asked "whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not." The answer is yes. Non-sealed lamps meeting the requirements of SAE J584 are acceptable, including those with two bulbs, as the "At-Focus Tests" paragraph of J584 is directed to "light source or sources."

Your next question is whether photometric compliance is judged when one light is on or two, including the maximum permissible output of 75,000 cd. The answer to this question depends on the design of the lamp; if it is designed so that both bulbs operate simultaneously, then photometrics including maximum output are determined with both bulbs operating. If the design is such that one bulb produces lower beam and the other the upper beam, then compliance is judged by that method of operation. Should one bulb produce both lower and upper beams and the other bulb perform an unregulated lighting function, then the photometric compliance would be judged with only the bulb used for the regulated function. In this case, however, the unregulated bulb must not interfere with the effectiveness of the headlamp. This also answers your final question about conduct of the out-of-focus test. It is to be conducted according to the design intent of the operation of the headlamp, i.e. the design function of each bulb or bulbs.

You have also asked about the geometrical center of a design when one of two bulbs (both with an upper beam and a lower beam filament apparently) is on. Operation of only one bulb alone would result in an assymetrical lighting display off the vehicle's centerline. This is permitted by S4.1.1.34 of Standard No. 108 for the sealed beam lighting systems specified therein. Therefore, we could not logically disapprove of it for unsealed headlighting systems. However, if only one bulb performed both the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper beams must be located on the vehicle's vertical centerline.

If you have any further questions, we shall be happy to answer them.

Sincerely,

Frank Berndt Chief Counsel

November 13, 1984

Mr. Frank Berndt, Chief Counsel Office of Vehicle Safety Standards, National Highway Traffic Safety Administration, DOT, 400 Seventh Street, S.W., Washington, D.C. 20590, U.S.A.

Dear Mr. Frank Berndt:

This is to ask you about interpretation and applicability of FMVSS 108 and SAE J584(Motorcycle Headlamp). Before asking questions, I'm pleased to introduce our organization. International Trade and Industry Inspection Institute (ITIII) is an affiliated inspection organization of Ministry of International Trade and Industry, Japanese Government and has three main functions. ITIII itself conducts test and inspections of industrial products under the control of MITI and ITIII administrates private inspection organizations, consumer bodies and manufacturers in terms of inspection and test. ITIII also is involved in the drafting process of inspection standards and inspection method of industrial products. ITIII has been an approved laboratory of lighting equipments by American Association of Motor Vehicle Administrators (AAMVA) and we have regular visits of Mr. Bardel and Mr. Cardarelli from AAMVA. We keep close relations with AAMVA for many years.

Inquiry

FMVSS 108 S4. 1. 1.34 specifies acceptable lighting system of motor cycles. This arises the question of whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not. If it is acceptable, we have three questions to ask you further with regard to SAE J584.

Question 1

Which case should non-sealed beam lamp comply with specified photometric value of SAE J584 either when one bulb is lighted on or two bulbs are on? How should we interpret the requirement of Maximum 75000 cd in each case?

Question 2

Which should be the case of geometrical center when one bulb is on as illustrated below?

"INSERT GRAPHIC"

Question 3

How should we conduct out of focus test of the applicable case asked in question 1?

I hope this contact will be the first step to create good relation with your organization and I appreciate your quick response to our question.

Best regards,

Kazutoshi Kasagi

Chief Inspector, Internationally Agreed Safety Division