Interpretation ID: 18369.ztv

Masao Muraoka, Deputy General Manager
Technical Administration Department
Koito Mfg. Co., Ltd.
Shizuoka Works
500, Kitawaki
Shimuzu-Shi, Shizuoka-Ken
Japan

Re: Interpretation of Replaceable Bulb Headlamp

Dear Mr. Muraoka:

This is in reply to your letter of July 3, 1998, to the Associate Administrator for Safety Performance Standards, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. In the future, please address requests for interpretation to the Chief Counsel.

You have called our attention to Standard No. 108's definition of "replaceable bulb headlamp," which means

"a headlamp comprising a bonded lens and reflector assembly and one or two replaceable light sources, except that a headlamp conforming to paragraph S7.8.5.2 or paragraph S7.8.5.3 may have a lens designed to be replaceable."

According to your letter, Koito is considering manufacturing a replaceable bulb headlamp "whose lens is bonded not with one adhesive agent, but with using some screws or clamps." The lens is separable from the lamp body for purposes of recycling, and Koito has no intention of providing a replacement lens. The chemical resistance test (S8.10.1) and the corrosion test (S8.10.2) apply to replaceable bulb headlamps with replaceable lens. You ask for an interpretation that the headlamp design Koito contemplates is not required to meet these two tests.

Although Standard No. 108 does not define a "bonded lens and reflector assembly," we use that term to denote a connection which is indivisible and permanent, such as provided by adhesives, rather than a connection that is divisible and impermanent such as provided by screws and clamps. I enclose a copy of an interpretation from the Chief Counsel, dated January 13, 1987, to Dr. Ernst of Hella KG Hueck & Co. explaining the agency's views.

Because the lens/reflector assembly is not bonded, and the lens is separable from the reflector, we regard this as a headlamp with a replaceable lens. Unless the headlamp complies with S7.8.5.2 or S7.8.5.3, it would be neither a "replaceable bulb headlamp" nor an "integral beam headlamp" as defined by Standard No. 108. This means that the headlamp could not be used in applications where certification of conformance to Standard No. 108 is required.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d..9/11/98