Interpretation ID: nht87-2.5

TYPE: INTERPRETATION-NHTSA

DATE: 06/10/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Anonymous (confidential)

TITLE: FMVSS INTERPRETATION

TEXT: Dear This is in reply to your letter of March 13, 1987, with respect to whether a new headlamp design is permissible under Motor Vehicle Safety Standard No. 108.

In the new design, the upper aiming pad is integral with the lens but it recessed and concealed by the lip of the hood. Thus, the hood must be open for a mechanical aimer to be applied. You believe that this is not precluded by section 5.1 of SAE J580 in corporated by reference in Standard No. 109, which requires aiming to be effected "without the removal of any ornamental trim rings or other parts."

Your drawing indicates that the flange is part of the headlamp lens even though that portion of the lens is not needed to provide illumination. The fact that the hood must be raised in order to aim the headlamps does not constitute a "removal" within the meaning of SAE J580. Therefore this design is not prohibited by Standard No. 108.

In accordance of your letter of April 27, 1987, your request for confidentiality is granted to the extent that all information which might identify you or your employer will be deleted from the publicity available copies of this letter.

Sincerely,

Erika Z. Jones Chief Counsel

Ms Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590 13 March 87 Dear Ms Jones

RE: INTERPRETATION OF FMVSS NO. 108, LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT REFERENCES SAD J580, SECTION 5.1 AUG 79

REQUEST FOR CONFIDENTIALITY - HEADLAMP LENS AND AIMING PAD DESIGN

the of the passenger car seeks a legal interpretation of FMVSS No.108; referen ced SAE J580 Aug 79, Sealed beam headlight assembly and confidentiality of its new headlamp lens and aiming pad design. SAE 580, Section (5.1) states, "Headlamps shall be de signed so that they may be inspected and aimed by mechanical aimers as specified in SAE 602 c (December 1974) without the removal of any ornamental trim rings or other parts."

is proposing a replaceable bulb type headlamp system with the upper aiming pad integral with the lens but recessed and concealed by the lip of the hood as shown in the attached drawing. It is, opinion that our lamp design is permissible under FMVSS No. 108 referenced SAE 580 Section 5.1. That is, if it is acceptable to raise the hood to adjust headlamp so should it be permissible to raise the hood to attach mechanical aimers.

For this reason requests a legal interpretation of SAE J580, Section 5.1 and request confidentiality of our headlamp design described and shown herein. Yours Sincerely Chief Engineer INSERT GRAPHIC