Interpretation ID: nht92-7.14

DATE: May 6, 1992

FROM: Peter K. Brown -- President, KC HiLites

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/15/92 from Paul J. Rice to Peter K. Brown (A39; Std. 108)

TEXT:

I wrote to you in April of 1990, regarding your opinion and interpretation of the law relative to hi and low beam headlight use.

The product in question is called, the quad beam and we have been selling it now since mid 1990, directed at vehicles with 4 headlamp systems.

In as much, as vehicles with 2 headlamp systems represent a good part of the vehicle population, and that most of the 2 headlamp equipped vehicles, use only the low beam filaments when on low beam and only the high beam filament when high beam is selected, has prompted me to write to you again.

Our quad beam will enable the low beam to work in conjunction with the high beam, which will dramatically increase the amount of light output.

My question then is, can our product legally be used on two headlamp systems, either sealed beam or replaceable bulb type?

I appreciate your help on this. I am including a copy of your previous letter for your reference.