Interpretation ID: nht89-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 05/22/89

FROM: H. HASEGAWA -- AUTOMOTIVE LIGHTING ENGINEERING CONTROL SECT. STANLEY ELECTRIC CO LTD

TO: RICHARD L. VAN IDERSTINE -- SAFETY STANDARDS ENGINEER U.S. DOT, NHTSA OFFICE OF VEHICLE SAFETY STANDARDS

TITLE: REVISION OF FMVSS NO. 108 (DOCKET NO. 85-15 NOTICE 8)

ATTACHMT: ATTACHED TO LETTER DATED 06/19/89 FROM STEPHEN P. WOOD -- NHTSA TO HASEGAWA; REDBOOK A33 [3]; STANDARD 108; DOCKET 85-15 NOTICE 8

TEXT: Dear Mr. Van Iderstine,

We appreciate very much for your kind cooperation during our stay in the U.S. for SAE Lighting Commity Meeting.

We have two questions on Revision of FMVSS No. 108 (Docket No. 85-15 Notice 8) which was finally issued on Federal Register of May 9, 1989.

- Question -

1. Please advice us the effective date of the requirement of S7.7.5.1 a). We suppose that S7.7.5.1 will be applied to the all headlamp with external aiming system (including replaceable bulb type headlamp).

However, this requirement was not applied for replaceable bulb type headlamp by previous FMVSS No. 108.

Therefore, we think that addition of new requirement need longer interval of effectiveness.

2. The requirement of S7.7.5.1 b) used quote SAE J580b "Sealed Beam Headlamp Assembly" by previous FMVSS No. 108 and the expression is little bit different from new S7.7.5.1 b).

Please advice us that the requirement of "0.1 in. max." will be determined, either during the test or after the test?

We would like to have your advice by facsimile.

Our facsimile number is 03-792-0007 (JAPAN).

Sincerely yours,