Interpretation ID: 24157.ztv

Robert G. Mills, Supervisor, Homologation
Triumph Motorcycles, Ltd.
Jacknell Road
Hinckley, Leicestershire LE10 3BS
United Kingdom

Dear Mr. Mills:

This is in reply to your fax of March 14, 2002, asking three questions with respect to Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (FMVSS No. 108). Pursuant to our request, you provided supplemental information on April 17, 2002.

Your questions are:

"1. If an SAE recommended practice that is referenced in FMVSS 108 is revised and updated by SAE, is the latest revision . . . automatically adopted in FMVSS 108? If not, does an earlier dated version remain in the regulation?

SAE materials that are referenced and subreferenced in FMVSS No. 108 are not automatically updated when the SAE revises them, and "earlier dated versions" remain in effect. That is because an SAE update requires an amendment to FMVSS No. 108 in order to be incorporated as a requirement. Under U.S. law, amendments to Federal regulations such as FMVSS No.108 must be proposed for public comment before they can be adopted.

2. You describe a new headlamp design and ask for confirmation of your conclusion that it complies with S7.9.6.2(b) of FMVSS No. 108.

Paragraph S7.9.6.2(b) requires that:

"If the [motorcycle headlamp] system consists of two headlamps, each of which provides both an upper and lower beam, the headlamps shall be mounted either at the same height and symmetrically disposed about the vertical centerline or mounted on the vertical centerline. If the headlamps are horizontally disposed about the vertical centerline, the distance between the closest edges of their effective projected luminous lens areas shall not be greater than 200mm (8 in)."

In your design, there would be "two visibly separate headlights" which would be placed "in one seamless housing," each headlamp providing an upper and lower beam, and each lamp placed symmetrically about the vertical centerline. Further, "[o]n each side, there will be clear cover placed over the outside of the lamp." You believe that this headlamp design is allowable but report that your supplier disagrees. In his view, a headlamp is permitted a maximum of two bulbs, and that use of a single housing effectively creates a four-bulb headlamp which is not permitted.

We evaluated a similar situation in our letter of February 22, 1999, to Tadashi Suzuki of Stanley Electric Co. (copy enclosed). Our letter commented that "it is possible to design a headlamp with a single lens but with separate housings and chambers; this type of design would effectively create two headlamps." However, the supplementary information that you furnished clarifies that the Triumph headlighting system is designed to be installed in a single housing, and that the upper and lower beam headlamps are not separable from the housing. This design differs from that posited by Stanley and, in our opinion, could not be considered a two-lamp headlamp system. As such, the requirements of S7.9.6.2(b) do not apply to this design, and Triumph needs to ensure that this headlamp complies with the requirements of S7.9.6.2(a).

We would like to further comment that a headlamp with four light sources is permitted as a motorcycle headlamp. While there is a limitation on the number of light sources for motor vehicle headlamps, there is no limitation for motorcycle headlamps.

"3. Table IV of FMVSS 108 states that the minimum separation distance between a turn signal and a headlight must be 4 inches. However, since turn signals must comply with the requirements of SAE J588, does the factoring table in SAE J588 apply if we want to mount the turn signals closer to the headlights than 4 inches? If is difficult for us to decide if close mounting of turn signals is permissible as FMVSS [108] appears to preclude mounting turn signals closer than 4 inches yet J588 gives you a possibility to do so."

We were asked this question by BMW in a letter of August 15, 1983, and I enclose a copy of our response to Karl-Heinz Ziwicka. The interpretation remains valid. The minimum spacing requirements established by Table IV between motorcycle headlamps and turn signal lamps must be met, for the reasons expressed in our letter, notwithstanding the fact that SAE J588 NOV84 and its predecessor in effect at that time permit a closer spacing of these lamps if a multiplier is applied to the minimum luminous intensities.

Sincerely,
Jacqueline Glassman
Chief Counsel

Enclosures
Ref:108
d.5/24/02