Interpretation ID: nht91-7.37

DATE: December 9, 1991

FROM: Hanno Westermann -- Hella KG Hueck & Co.; Olaf Schmidt -- Hella KG Hueck & Co.

TO: Richard L. van Iderstine -- NHTSA

TITLE: Definition of 2 or 4 Headlamp System

ATTACHMT: Attached to letter dated 3/5/92 from Paul Jackson Rice to Herrn. Westermann u. Schmidt (A39; Std. 108)

TEXT:

Since the great revision of FMVSS No. 108 by Docket 85-15, Notice 12 of February 8, 1990, we are missing a paragraph clarifying the definition of a 2 or 4 headlamp system respectively.

In the former version of 108, this definition was done under para. S4.1.1.36, but today there only remains figure 26, which explains the application of photometric requirements with respect to the bulb or bulb combination used.

We assume that no changes to the sense of 108 have been made for this matter so that our remarks could be added to FMVSS 108 by short term to avoid the current discrepancies between headlamp manufacturers and the test laboratories.

Attached you will find a sketch representing our understanding of the definition of a 2 or 4 lamp system, deriving from the former 108.

Many thanks for your endeavours in this and

A Merry Christmas and a Happy New Year.

Attachment

Drawings of Replaceable Bulb Headlamp Systems. (Graphics omitted)