Interpretation ID: aiam3787
Hella
Inc.
P.O. Box 1064
Cranford
NJ 07016;
Dear Mr. Suuronen: This is in response to your letter of November 30, 1983, clarifyin your earlier requests for an interpretation of Standard No. 108. You have asked whether replaceable bulb headlamps may be manufactured in sizes identical to the current sizes for sealed beam headlamps, provided that they meet Standard No. 108 in all other respects.; The replaceable bulb headlamp amendment was adopted with the intent o allowing vehicle manufacturers greater flexibility in the front end design in order to improve aerodynamics. The amendment allows an original equipment two-lamp system of no specified dimensions, and replacement lamps for these systems. It was not directed towards replacement lamps for existing headlamp systems. However, because no exterior dimensions for headlamps are specified by the amendment, replaceable bulb headlamps intended for use in a two-lamp system, with exterior dimensions of sealed beam round or rectangular two-headlamp systems, would be permissible assuming that they meet all other requirements of Standard No. 108, including proving one of the two aiming pad locations specified for replaceable bulb headlamps. However, until Standard No. 108 is amended to allow a four-lamp replaceable bulb headlamp system, these lamps are precluded from being manufactured to replace today's sealed beam round and rectangular sealed beam headlamps used in four-lamp systems.; I hope this provides the clarification you seek. Sincerely, Frank Berndt, Chief Counsel