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Interpretation ID: nht95-3.88

TYPE: INTERPRETATION-NHTSA

DATE: August 11, 1995

FROM: Yoshiaki Matsui -- Manager, Automotive Equipment, Legal And Homologation Section, Stanley Electric Co., Ltd.

TO: Chief Counsel -- NHTSA

TITLE: Headlamp system containing fog lamp

ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JOHN WOMACK TO YOSHIAKI MATSUI (A43; REDBOOK 2; STD. 108)

TEXT: We are planning to develop headlamp systems that produce high beam, low beam and fog lamp beam. The fog lamp is reciprocally incorporated with the high beam headlamp, using one dual-filament bulb (ex.; HB2). The high beam and the fog lamp will not be l it simultaniously. Please refer to the attached drawing for the possible operating conditions.

The FMVSS No. 108 specifies no requirement for fog lamp, except that the lamp shall not impair the effectiveness of lighting equipment required by the Standard. (S5.1.3) And we believe such a combination we are planning will not impair the effectiveness of the headlamp.

We would like to ask you to give your advice whether such a combination of fog lamp and high beam can be accepted under the FMVSS No. 108.

Your answer will be highly appreciated.

(Drawing omitted.)