Interpretation ID: nht89-2.5

TYPE: INTERPRETATION-NHTSA

DATE: 06/16/89

FROM: TAKAYOSHI CHIKADA -- MANAGER OF AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC

TO: RICHARD L. VAN IDERSTINE -- SAFETY STANDARDS ENGINEER

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

ATTACHMT: ATTACHED TO LETTER 08/23/89 FROM STEPHEN P. WOOD -- NHTSA TO TAKAYOSHI CHIKADA; REDBOOK A34[3]; STANDARD 108

TEXT: Dear Mr. Van Iderstine,

We thank you very much for your kind cooperation during our stay in the U.S. for SAE Lighting Committee Meeting.

We would like have your advice concerning interpretation of new FMVSS No. 108 (Docket No.85-15 Notice 8).

1. The requirement of S7.7.5.1.a) was not applied to replaceable type headlamp by previous FMVSS No.108. Please give us your advice whether this requirement will also be applied to the replaceable bulb type headlamps which are already manufactured accor ding to the previous FMVSS No.108.

2. The requirement of S7.7.5.1.b) need to quote SAE J580 b "Sealed Beam Headlamp Assembly" by previous FMVSS No. 108 and the expression seem to be slightly different from new S7.7.5.1.b). Please advice us whether the requirement of "0.1 in. max." is cond itioned when headlamp is being pushed or after said force is removed.

3. How should we prove the confirmation to the requirement of S7.7.2.2? We think the combinations of Horizontal and Vertical angle within the aim range will be so huge and it is not practicable to test for all combinations.

4. It is acceptable to set up initial "0" point of S7.7.5.2.a).2) not mechanically but photometrically?

Please give us your advice by return facsimile.

We thank you very much in advance.

Yours faithfully,