Interpretation ID: aiam4609
FAX 03-792-0007 (Japan) Dear Mr. Hasegawa: This is in reply to your FA letter of May 22, l989, to Richard Van Iderstine of this agency. You have two questions with respect to the amendment to Standard No. l08 published on May 9, l989 (Docket No. 85-15, Notice 8). Your first question is the effective date of paragraph S7.7.5.1.(a), which you point out was not previously a requirement of Standard No. l08. You suggest the need for a delayed effective date (but give no reason why one may be needed). Paragraph S7.7.5.1(a) will be effective June 8, l989. Although the requirement is a new one (the restriction on motion of a headlamp when an external aiming device is applied to it), it was proposed as part of the December 29, l987 NPRM, and no comments received indicated a need for a delayed effective date. Your supposition is correct, S7.5.5.1 will apply to all headlamps with an external aiming system, including those incorporating replaceable bulbs. Your second question relates to paragraph S7.7.5.l(b), and you ask 'whether the requirement of '0.1 in. max.' will be determined, either during the test or after the test'. In pertinent part, subsection (b) states 'nor shall the lamp recede more than 0.1 in. (2.5 mm) after being subjected to an inward force....' This means that the measurement is determined after the test. Sincerely, Stephen P. Wood Acting Chief Counsel /;