Interpretation ID: nht74-1.27

DATE: 03/14/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Ichikon Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 25 to Mr. Charles A. Baker of this Office concerning the performance requirements of automotive lamp bulbs.

The answers to your specific questions follow.

"(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE (Illegible Word) subreferenced in the current FMVSS 108 as well as lighting devices?"

The answer is no. The lamp bulbs installed in production lamps or lighting devices are not included in the requirements of FMVSS No. 108. The requirements apply only to the lamp assembly (the reflector, lens, and associated components other than the bulb) when tested with a selected lamp bulb that (Illegible Words) and the specifications of paragraphs S4.1.1.19 and S4.1.1.20 of Standard 108.

"(2) In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?"

The proposal in Docket (Illegible Word) Notice 3 was in paragraph 57.6 which referenced the 1972 edition of the SAE Handbook. SAE (Illegible Word) was included in this Handbook, and is, therefore, the reference for test bulbs in the proposal.

"(3) Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?"

No such consideration is necessary, because, as indicated above SAE J573d is only a specification for the test bulbs used for the photometric tests of the lamps.

We trust that these answers are satisfactory; however, please feel free to contact us in case of future questions.

Sincerely,

Not controlled

ICHIKOH INDUSTRIES, LTD.

February 25, 1974

Charles A. Baker -- Acting Chief Division of Lighting and Vision, National Highway Safety Bureau Department of Transportation

Dear Mr. Baker, Subject: Performance Requirements of Automotive Lamp Bulbs

As you awaire, SAE Standard J573, Lamp Bulbs and Sealed Units, was revised from J573d to J573e, and SAE Recommended Practice J1049, Service Performance Requirements and Test Procedure for Motor Vehicle Lamp Bulbs was newly issued on August, 1973 respectively.

These revision and new issue confuse us in respect the conformity to FMVSS 108 in production of the bulbs.

Then we would like to ask you the following questions regarding the interpretation of the current FMVSS 108 and the proposed FMVSS 108A.

(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE J573d subreferenced in the current FMVSS 108 as well as lighting devices?

(2) On the otherhand, the final rule for proposed FMVSS 108A (Docket No. 69-19: Notice 3) is expected to issue in early 1974.

In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?

(3) We think that SAE J573 was established in the nature of design standard and revised as the specification of bulbs for photometric test of lamps. We think further that SAE J1049 was issued as the survice use of bulbs.

Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?

Your early reply would be highly appreciated.

Very truly yours,

Yoshio Horii, Manager -- Lighting Engineering Dept.