Interpretation ID: 1983-2.49

TYPE: INTERPRETATION-NHTSA

DATE: 08/23/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Autodrome de Linas-Montlhery/Union Technique de L'Automobile du Motorcycle et du Cycle (H. Le Guen)

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Le Guen Laboratory Director Union Technique de L'Automobile du Motocycle et du Cycle Autodrome de Linas-Montlhery Linas, 91310 Montlhery France

Dear Mr. Le Guen:

This is in reply to your letter of July 27, 1983, to Mr. Vinson of this office asking several questions with respect to the amendment of Standard No. 108, June 2, 1983, which permits semi-sealed replaceable bulb headlamps.

First, you mention certain sealing specifications, contrasting them with references to designed openings, and ask for our comments on this. Although the design that Ford intends to use is not a vented system, the amendment does not specify or prohibit either vented or unvented systems. A vented system using the standardized replaceable light source and the O-ring seal is permissable if the headlamp passes all the recently adopted environmental tests.

With reference to your further questions, there are no tolerances on the dust test. You have also asked whether, assuming that a European type headlamp using the new light source "passes all tests mentioned in the amendment to F.M.V.S.S. 108, would it get D.O.T. approval?" If the lens-reflector unit is bonded, and if with the light source inserted the lamp meets U.S. photometric requirements and all environmental tests specified in the amend-ment, then the manufacturer of the lamp may apply the D.O.T. symbol to it. This is the certification that the lamp meets all applicable U.S. Federal motor vehicle safety standards. Under this self-certification process, the manufacturer, rather than D.O.T., approves the lamp for sale.

Finally, you have asked who will manufacture the new bulb and where you might be able to obtain test samples. Ford's initial supplier will be Sylvania/GTE, and you may write GTE Products Corp., West Main Street, Hillsboro, NH 03249, Attn: Mr. Richardson.

I hope this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

LINAS, July 27, 1983

Mr. TAYLOR VINSON NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street S.W. WASHINGTON D.C. 20590 U. S. A.

Our ref. HLG/RR/JP/83.1159.33 Signed by: Mr. RENDU

Dear Mr. VINSON,

After reading over pages 24690 to 24716 of the 02 June 1983 Federal Register an interesting discrepancy come up. On the first page (24690), second column lines 10 and 61, and the third column line 62 of the same page, indicate the new plastic headlamp is to be semi-sealed, the opening (for the bulb) non-sealed, the bulb being the sealing piece with its "O" ring seal. Later in the text, page 7 (24696), third column, line 46, (corrosion) mentioned are "drainholes, breathing devices, and other designed openings that are to be in their normal positions" during testing.

If you could please comment on this point and possibly clarify this new standard this would be most helpful to us. In addition, if you could please comment on : Are there any tolerances in the "dust test" ? If a glass lens, metal reflector, European type headlamp, (using the new standard bulb) passes all tests mentioned in the Amendment to F.M.V.S.S. 108, would it get D.O.T. approval? And who is going to manufacture, and where would we able to obtain a sample of the new "standard" bulb?

Thank you very much for your assistance and we hope to hear from you soon.

Sincerely,

H. LE GUEN LABORATORY DIRECTOR