Interpretation ID: nht88-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/88

FROM: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: HEADLAMP COMBINATIONS - REQUEST FOR CLARIFICATION, FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 TO GEORGE ZIOLO FROM ERIKA Z JONES; REDBOOK A32, STANDARD 108;

TEXT: Dear Ms. Jones:

I assist graymarket automobile importers in conforming their vehicles.

Some foreign models come equipped with four headlamps two of which are 7" diameter and two 5 3/4" diameter.

My clients modify them by installing two Type 2D1 (7" dia) high & low beam units outboards, and two Type 1C1 (5 3/4" dia) high beam units inboards.

OVSC (NEF-32) rejects such installations because they are "nonconforming" "headlighting systems". It is my opinion that such rejection is without basis.

As I understand it, the FMVSS are "minimum standards". S4.1.1 confirms this by requiring that "...each vehicle...be equipped with at least the number of lamps...specified in Tables I and III,...."

My clients' installation of two Type 2D1 lamps satisfies the minimum requirement specified in Table III.

My clients' installation of two Type IC1 lamps in addition to the two Type 2D1 lamps is not counter to a "headlighting system" as I can find in the standard. In addition, S4.4 appears to permit such combination.

While it may have been necessary to ensure symmetry in headlighting systems combinations in motorcycles by way of S4.1.1.34, where Table III calls for only one lamp, such clarification relative to vehicles other than motorcycles is obviously not needed s ince symmetry in such will be natural.

I therefore kindly request that you determine whether or not FMVSS 108 allows lamp combinations as outlined above and advise me at your earliest convenience. The cited lamp combinations are desired by my clients for reasons of appearance. Also, modificat ion of such vehicles to delete the 2D1 (7") lamp in lieu of a 2C1 (5 3/4") lamp is costly, including replacement of the entire front grille.

Sincerely,

FEDERAL REGISTER VOL 52, NO 208 10/28/87 NHTSA 49 CFR PART 571 (DOCKERT 87-15 NOTICE 1) FEDERAL MOTOR VEHICLE SAFETY STANDARDS, VEHICLE CLASSIFICATION (TEXT OMITTED)