Interpretation ID: nht90-3.44

TYPE: Interpretation-NHTSA

DATE: August 2, 1990

FROM: Paul Jackson Rice, NHTSA

TO: T. Spingler, Robert Bosch GmbH

TITLE: None

ATTACHMT: Letter dated 7-19-90 to R. v. Iderstine from T. Spingler; (OCC 5014)

TEXT:

This is in reply to your FAX of July 19, 1990, to Richard Van Iderstine of this agency asking for confirmation of an oral interpretation provided you by Jere Medlin, Office of Rulemaking, with respect to replaceable bulb headlamps.

Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, defines (section S3) a replaceable bulb headlamp as "a headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sour ces." In Europe you fix the lens to the reflector assembly with a rubber seal and clips. For the U.S. market you propose to add "silicone-glue at four places between lens and housing to prevent removal of the lens." Mr. Medlin informed you that this w ould be a "bonded lens and reflector assembly."

The standard does not define "bonded", but the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable. Any method of adhesion that accomplishes this would be a sufficient bond for purposes of the d efinition. If the application of silicone glue at four places between the lens and the reflector assembly is sufficient to prevent manual separation of the lens from the assembly, then it would be a sufficient bond.

I hope that this answers your question.