Interpretation ID: aiam4359
Manager
Technical Administration Dept. Koito Mfg.
Ltd.
Shizuoka Works
500
Kitawaki
Shimizu-Shi
Shizuoka- ken
Japan;
Dear Mr. Iwase: This is in reply to your letter of March 24, 1987, asking two question with respect to Motor Vehicle Safety Standard No.108; Your first question concerns an aiming adaptor for replaceable bul headlamps whose lenses may slant 60 degrees from the vertical or horizontal. You have discovered that the Hopkins universal adaptor cannot be used with these headlamps, and you propose to provide a special adaptor with each vehicle equipped with such headlamps, as well as aiming adjustment procedure information in the vehicle's service manual. You ask for confirmation of your belief that this is permissible under Standard No. 108.; Standard No. 108 does not require that an aiming adaptor be provide with a motor vehicle, only that its headlamps be capable of mechanical aim. Therefore there is no legal requirement that the adaptor be provided. However, without such an adaptor, an owner of a vehicle with the 60-degree headlamps may encounter difficulties of State inspection stations where mechanical aimers are in use, and at repair facilities when headlamps are replaced or after body work has been performed that necessitates reaim of headlamps. Therefore we believe that provision of the adaptor and aiming information would enhance consumer acceptance of the 60- degree headlamps.; Your second question concerns the legality of the upper aiming boss o a low profile headlamp. Because the height of the lens is insufficient to incorporate the upper aiming boss, you propose to place it on a flange of the lens in a 'photometrically ineffective area.' However, the flange is concealed when the hood is shut, and the hood must be opened in order for aiming adjustment to occur. You believe that this is acceptable under Standard No. 108. and ask for confirmation.; Paragraph S4.1.1.36 (a)(2) requires that 'the lens of each replaceabl bulb headlamp shall have three pads which meet the requirements of Figure 4....' Your drawing indicates that the flange is part of the headlamp lens even though that portion of the lens is not needed to provide illumination. Therefore this design would appear to meet the requirements of Figure 4 as you have concluded.; Sincerely, Erika Z. Jones, Chief Counsel