Interpretation ID: aiam2878
Director/General Manager
Factory Representative Office
Toyota Motor Sales
U.S.A.
Inc.
One Harmon Plaza
Secaucus
NJ 97094;
Dear Mr. Kawano: This is in reply to your letter of September 6, 1978, requesting a interpretation of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the 'K' dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.; You further advised that the proposed design would not interfere wit the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.; Since Figure 8(B) of SAE J571d shows that the 'K' dimension shall no exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.; Sincerely, Joseph J. Levin, Jr., Chief Counsel