Interpretation ID: nht88-2.70
TYPE: INTERPRETATION-NHTSA
DATE: 07/14/88
FROM: SADATO KADOYA -- MANAGER, SAFETY -- ENGINEERING, MAZDA
TO: ERIKA Z. JONES -- OFFICE OF CHIEF COUNSEL, NHTSA
TITLE: REQUEST FOR INTERPRETATION - FMVSS 108; LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT - AUXILIARY LAMPS
ATTACHMT: MEMO DATED 11-3-88, TO SADATO KADOYA, FROM ERIKA Z. JONES, STD 108; ALSO ATTACHED, MEMO DATED 7-14-88, RE: REQUEST FOR CONFIDENTIAL TREATMENT OF INFORMATION-49 CFR PART 512, CONFIDENTIAL BUSINESS INFORMATION
TEXT: Mazda is currently developing a lamp mechanism that features movable reflectors which can expand the area of illumination according to the driving steering angle on curved roads. The purpose of such a mechanism, when incorporated into the vehicle forwar d lighting system, is to better illuminate the forward curved path of the driver, and to therefore improve night-driving safety on winding roads.
To insure that such a system will be in compliance with all applicable safety standards, Mazda would like to confirm its interpretation of FMVSS 108; Lamps, Reflective Devices, and Associated Equipment.
In Mazda's proposed system, an electronic control unit adjusts an additional reflector's position to as much as thirty degrees to each side of the zero degree position in accordance with changes in steering angle. Automatic return of the reflectors t o the zero position occurs when the steering angle returns to zero degrees.
According to our interpretation of FMVSS 108, headlamps cannot be equipped with adjustable reflectors (S4.1.1.36). The only relevant provision applicable to fog lamps and cornering lamps is the requirement that they not impair the effectiveness of re quired vehicle lighting equipment (S4.1.3). Are we correct in concluding that although it will not be possible to introduce our adjustable reflector lamp as a headlamp, it may be possible to introduce it as a fog or cornering lamp, assuming the above pr ovision is met?
We would appreciate your interpretation of these issues at your earliest convenience. Please do not limit your discussion to the above regulations, but also address any other regulations and automotive safety considerations that might be pertinent.