Interpretation ID: 17697.ztv

Tadashi Suzuki, Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153,
Japan

Dear Mr. Suzuki:

This is in response to your letter of April 2, 1998, asking for confirmation of the acceptability under Standard No. 108 of Stanley's new visual/optical headlamp system.

The system is based upon an existing system aimed by VHADs. In the new system, the VHAD for vertical aim has been removed. The horizontal aiming mechanism is "deleted by removing the horizontal VHAD and by fixing a cover on the head of the aiming bolt so that the access is impossible." The requisite marks are on the lenses identifying it as a visually/optically aimable headlamp..

You note the remarks in the preamble to the final rule on visually/optically aimable headlamps that "any current headlamp design that is modified to include visual/optical aimability must still provide mechanical aimability if that headlamp is intended to be a replacement in vehicles in which the lamp was used before its redesign." You inform us that this headlamp is intended for a new model year vehicle and that the existing type of headlamp will be provided for the replacement of the present model year of vehicle. The two headlamps will have different parts numbers and lens identifiers. Under these circumstances, you have asked for an interpretation that the new system need not continue to provide mechanical aimability.

It is not advisable for headlamps on the same vehicle to have be aimed by two different means. However, in this situation, where the two headlamps have different parts numbers and lens identifiers, we have concluded that Stanley is justified in concluding that the visually/optically aimable headlamp is not a replacement for the headlamp that is mechanically aimable, and therefore need not retain the mechanical aiming feature on the newer headlamp. We believe that Stanley's intent would be even clearer if the cartons in which each type of replacement headlamp is shipped are marked to identify the specific model year(s) for which replacement is intended.

Sincerely,
Frank Seales, Jr.
Chief Counsel
NCC-20 ZTVinson:mar:5/30/98:62992:OCC 17697
interp. 108; redbook (2)
NCC-20 ZTVinson:mar:5/21/98:62992:OCC 17697
cc: NCC-01 Subj/Chron
ztv; 17697; U:\ncc20\interp\108\17697.ztv