Interpretation ID: nht87-2.57
TYPE: INTERPRETATION-NHTSA
DATE: 07/23/87
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: M. Iwase -- Manager, Technical Administration Dept., Koito Mfg. Co. Ltd.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. M. Iwase Manager, Technical Administration Dept. Koito Mfg. Co.. Ltd. Shizuoka Works 500, Kitawaki Shimizu-Shi, Shizuoka-ken Japan
Dear Mr. Iwase:
This is in reply to your letter of March 24, 1987, asking two questions with respect to Motor Vehicle Safety Standard No. 108.
Your first question concerns an aiming adaptor for replaceable bulb headlamps whole lenses may slant 60 degrees from the vertical or horizontal. You have discovered that the Hopkins universal adaptor cannot be used with these headlamps, and you propose t o provide a special adaptor with each vehicle equipped with such headlamps, as well as aiming adjustment procedure information in the vehicle's service manual. You ask for confirmation of your belief that this is permissible under Standard No. 108.
Standard No. 108 does not require that an aiming adaptor be provided with a motor vehicle, only that its headlamps be capable of mechanical aim. Therefore there is no legal requirement that the adaptor be provided. However, without such an adaptor, an ow ner of a vehicle with the 60-degree headlamps may encounter difficulties at State inspection stations where mechanical aimers are in use, and at repair facilities when headlamps are replaced or after body work has been performed that necessitates reaim o f headlamps. Therefore we believe that provision of the adaptor and aiming information would enhance consumer acceptance of the 60-degree headlamps.
Your second question concerns the legality of the upper aiming boss on a low profile headlamp. Because the height of the lens is insufficient to incorporate the upper aiming boss, you propose to place it on a flange of the lens in a "photometrically inef fective area." However, the flange is concealed when the hood is shut, and the hood must be opened in order for aiming adjustment to occur. You believe that this is acceptable under Standard No. 108 and ask for our confirmation.
Paragraph S4.1.1.36(a)(2) requires that "the lens or each replaceable bulb headlamp shall have three pads which meet the requirements of figure 4...." Your drawing indicates that the flange is part of the headlamp lens even though that portion of the len s is not needed to provide illumination. Therefore this design would appear to meet the requirements of Figure 4 as you have concluded.
Sincerely,
Erika Z. Jones Chief Counsel
Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Admin. 400 Seventh Ave., S. W. Washington D.C., 20590 USA
Dear Ms. E. Z. Jones
We would like to ask you the following question concerning aiming adjustment for bulb replacement headlamp.
RE: 1) Aiming Adaptor for 60o Slant Bulb Replaceable Headlamp
We are developing and engineering-designing of bulb replaceable headlamp whose lens slants up to about 60o in vertical and horizontal as shown below.
SEE HARD COPY FOR GRAPHIC ILLUSTRATION
Upon our technical review, we have come to conclusion that this headlamp would be able to meet with all of the requirements specified in FMVSS NO. 108.
This headlamp lens has three pads which meet the requirements of Figure 4, Group II Aiming Pad Location (prescribed for 1A1, 2A1 sealed beam unit) and is marked "22H62V" for aiming in accordance with S4.1.1.36-(a)(3) of FMVSS NO. 108.
This headlamp is designed, in accordance with S4.1.1.36(b)(3), so that it would be aimed by use of mechanical aimer specified in SAE J602C.
However, when this headlamp is installed onto the vehicle, the following inconvenience will come about to the aiming of this headlamp, we are afraid.
When user, dealer or vehicle inspection station try to perform aiming of this headlamp by use of the aimer specified in SAE J602C, the universal adaptor (Hopkin's smaller adaptor; stock #0203 - refer to the attached pamphlet) cannot be used onto this hea dlamp.
Because Hopkin's adaptor has the adjustable range in angle of suction cup which is limited within 35o max and adjustable length of legs within 4.0 in. max.
However, this headlamp requires 60o in its adjustable range and 6.2 in. in its adjustable length of legs.
For the above possible inconvenience, we have no other choice but to have each vehicle provided with a set of special adaptor for this headlamp (shown below) so that it could be made mechanical aiming adjustment by means of the aimer specified in SAE J60 2C, we think.
SEE HARD COPY FOR GRAPHIC ILLUSTRATION
The information of aiming adjustment procedures for this headlamp shall be put into vehicle service manual, we think.
Question-1):
We believe that this special adaptor and our countermeasure fully meet with FMVSS NO. 108 and have nothing illegal under FMVSS NO. 108.
We would like you to confirm that our interpretation is correct.
RE: 2) ARRANGEMENT OF AIMING BOSS FOR LOW PROFILE HEADLAMP
We are developing and engineering-designing such a low profile headlamp as the height of its lens is not enough to apply to the aiming boss arrangement in Fig. 4 of FMVSS NO. 108.
SEE HARD COPY FOR GRAPHIC ILLUSTRATION
Accordingly we have an idea to have aiming boss arranged as shown below.
SEE HARD COPY FOR GRAPHIC ILLUSTRATION
(1) The upper aiming boss is located on the flange of lens which is photometrically ineffective area.
(2) The aiming boss location is applied to Fig. 4 of FMVSS NO. 108.
(3) However, the upper boss is located in a part which is covered by the bonner and so the bonner must be opened when aiming adjustment is made.
Question-2):
We believe that the aiming boss arrangement as abovementioned can be applied to FMVSS NO. 108 and have nothing illegal under FMVSS NO. 108.
We would like you to review and confirm that it is correct.
Upon your review, your prompt reply to this matter would be greatly appreciated.
Sincerely
M. Iwase, Manager Technical Administration Dept. Koito Mfg. Co., Ltd. Shizuoka Works
Attached: Copy of Universal Adaptors Pamphlet
SEE HARD COPY FOR GRAPHIC AND ADDITIONAL TEXT INFORMATION