Interpretation ID: aiam4669
Kitawaki Shimizu-shi
Shizuoka-ken Japan;
Dear Mr. Iwase: This is in reply to your letter of August 22, l990, t Erika Z. Jones, formerly the Chief Counsel, requesting an interpretation of Standard No. 108. You state that section S7.7.5.2(a)(2)(iv) of Standard No. 108 requires that the horizontal indicator of a vehicle headlamp aiming device (VHAD) shall be capable of re-calibration over a movement of +/- 2.5 degrees, and you would like us to confirm our interpretation of the method and procedures of recalibration on the vehicle after repair from accident damage. You say that NHTSA 'interprets as follows: If the dimensional specifications of vehicle body and appropriate instruction are described in shop manual, re-calibration could be addressed.' (55 FR pages 4425 and 4426, February 8, l990). You stated that Koito did not believe that this method is practicable. We believe that you have misunderstood the Federal Register notice. The notice was the agency's response to petitions for reconsideration of Section S7.7.5.2(a)(2)(iv). Subsection (iv) states that the horizontal aim indicator of a VHAD 'shall be capable of recalibration over a movement of +/- 2.5 degrees . . . to accommodate any adjustment necessary for recalibrating the indicator after vehicle repair from accident damage.' Ford Motor Company had commented that this requirement was unduly restrictive. It asked NHTSA to allow the option of a VHAD with only a vertical aim indicator if the headlamps as installed met a suggested horizontal aim specification of 0.0 +0.8/-0.4 degree. NHTSA, believing in the importance of horizontal aim capablility, found that a principal area of concern was that circumstances could occur during the life of the vehicle that could adversely affect maintenance of correct horizontal aim, and that without horizontal aim capability, it was unclear that the accuracy of horizontal aim could be assured after repair of accident damage. It was at that point that NHTSA observed: 'Manufacturers could address this concern by providing dimensional data for precise structural alignment of the vehicle in shop manuals and appropriate instructions for performing the necessary and potentially extensive parts replacement and vehicle reconstruction requisite for correct horizontal aim.' However, NHTSA went on to say that this concern was already met by subsection (iv) which requires the horizontal aim indicator to be capable of recalibration after crash damage or vehicle repair. NHTSA denied Ford's petition. Thus, it did not propose or adopt a requirement, as Ford wanted, that a manufacturer could provide instructions in place of a VHAD with a horizontal aim indicator. The existing requirement of subsection (iv) remained unchanged. Thus, it is the manufacturer's decision on how to provide for recalibration after crash damage and vehicle repair. Therefore, as long as a VHAD complies with subsection (iv), a manufacturer may provide whatever re-calibration instructions it deems appropriate. I hope that this answers your question. Sincerely, Paul Jackson Rice Chief Counsel;