Interpretation ID: 2830o

Mr. Mamoru Arisaka Manager, Automotive Lighting Homologation Sect. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, JAPAN

Dear Mr. Arisaka:

This is in reply to your letter of July 7, 1988, with respect to a motorcycle lighting device called the "rolling headlamp." The headlamp is designed to have its vertical plane always perpendicular to the ground regardless of the inclination of the motorcycle. You have asked whether such a device is legally permissible.

Motor Vehicle Safety Standard No. l08 does not prohibit alteration of the mounting angle of a headlamp. Although paragraph S4.3.1 requires each lamp to "be securely mounted on a rigid part of the vehicle," your lamp appears to be "securely mounted" even if it is able to rotate.

I hope this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

/Ref:108 d:8/26/88