Interpretation ID: nht90-3.24
TYPE: Interpretation-NHTSA
DATE: July 19, 1990
FROM: Guy Dorleans -- Manager, Regulatory Affairs Department Division Eclairage-France
TO: P. J. Rice -- Chief Counsel, NHTSA
TITLE: Ref: gd 862 M90
ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-12-90 from P.J. Rice to M.G. Dorleans (A36; Std. 108)
TEXT:
Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108," Lamps, Reflective Devices and Associated Equipment ."
In its edition of May 9th 1989, the Federal Register Vol. 54 N 88 allows the use of lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. V aleo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:
"Aiming concept for headlamps. Solution 3." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car. These instructions will emphasize on the nov elty in using SAE J602 headlamp external aimers.
We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.
We would ask you to provide us with your confirmation of our interpretation of the Standard 108 in this matter. We are ready to demonstrate NHTSA a working prototype if you deem it necessary.
Upon your kind review to this matter, your promptly reply would be greatly appreciated.
Enclosure
July 19th, 1990
Aiming concept for headlamps. Solution 3. 1) Description of the headlamp.
The lens has 3 aiming pads on which can be attached a mechanical aiming device as per SAE J602 Oct 80. The housing contains a movable reflector, a horizontal aiming feature and a vertical aiming feature. These parts and the fixed point are designed so that there is no possibility to modify
the horizontal aim when aiming vertically, and vice versa.
The vertical aiming feature consists in two combined coaxial screw and nut, hereafter referred to as AV and BV:
AV is used on the assembly lines of the lamp manufacturer and also on the assembly lines of the car manufacturer. While the aiming plane is placed in its designed position, the low beam is photometrically aimed and the fiducial mark of BV is set to zero . The rotation of AV achieves this initial aim, while BV can not move. Then the cap is inserted. This cap can not be removed using simple tools. The repair shops and the dealers have the necessary equipment to remove the cap. AV is also the aiming f eature which must be used to repair the vehicle after accident damage.
BH is the aiming nut which must be used during normal reaim operations
The horizontal aiming feature is so designed that when a torque is applied to BV, AV rotates with the same angle. In other terms, the friction torque between BV and AV is far bigger than the friction torque between AV and the housing.
The horizontal aiming feature, consisting of a screw AH and a nut BH, uses basically the same principle as its vertical counterpart.
Both vertical and horizontal reaim features are permanently attached to the headlamp.
2) Vertical reaim.
A commonly available mechanical aimer must be used. This kind of aimer has been used in the US since the early '50s, and are available in each repair shop or dealers. Among them, the Hopkins B4A is a good example of easy-to-use external aimer, with aer odynamic headlamps capability thanks to its articulated vacuum cup and universal extender.
The ground surface must be substentially flat. The car must fulfill the requirements of SAE J 599 May '81.
2 1) Set to zero the fiducial mark on BV
2 2) Attach calibration fixtures to the aimers, place aimers at the centerline of each wheel on one side of the vehicle. Level each unit by adjusting screw on each calibration fixture.
2 3) Transfer the reading indicated on the horizontal dial to the floor level dial on each aimer. Set the "vertical" dial of each aimer at zero.
2 4) Remove calibration fixture
2 5) Check that universal extenders are set to the values engraved on the lens, and attach each mechanical aimer to its designated lamp. Check the sight openings face each other.
2 6) Rotate the "vertical" dial of each aimer intil the bubble is centered
in the vial. Tranfer to BV the value the "vertical" dials indicate for each side of the car.
3) Horizontal reaim.
3 1) The horizontal dials and the BH nuts must be set to zero.
3 2) Rotate each "horizontal" dials until the the split image of each aimer are aligned.
3 3) Respective of the side, transfer the readings of the aimers to the BH nuts.
4) After accident damage.
This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor must be rigid, flat and horizontal The special tools allow to remove the cap, thus giving access to the A H and AV screws. The BH and BV nuts being securely maintained in zero position, the operator:
4 1) Checks the angles of the aiming plane 4 2) Uses a screen at 7.6 m, or a fractional balance aiming machine, or a pair of string aimers.
Guy Dorleans Valeo Lighting.
Enclosure: 1
(Drawing attached, graphics omitted)