Interpretation ID: 17757.ztv

Frank Zalar, Quality Engineering & Regulatory Manager
General Electric Automotive Lighting
Worldwide Automotive Lighting Department
General Electric Company
1975 Noble Road, Nela Park
Cleveland, OH 44112-6300

Dear Mr. Zalar:

This is in reply to your letter of March 24, 1998, on optical axis markings for sealed beam headlamps.

Paragraph S7.8.1(b) of Federal Motor Vehicle Safety Standard No. 108 requires motor vehicles manufactured on or after September 1, 1998, to be equipped with headlamps which have a mark or markings to identify the lamp's optical axis that are visible from the front of the headlamp when installed on the vehicle. You present two types of markings for our consideration which you believe will satisfy this requirement.

The first headlamp lens marking is a "window" which is centered on the optical/mechanical axis of the lamp. We confirm that this is a sufficient marking under S7.8.1(b).

The second headlamp lens marking comprises "horizontal and vertical lines formed by flute edges of the lens the centermost of which denote the optical axis of the lamp." If the lamp does not employ horizontal flute edges at the lamp center, the headlamp center will be marked to indicate the optical axis. The intersection of the centermost horizontal and vertical lines also appear to be a sufficient marking under S7.8.1(b).

If you have any further questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.5/6/98