Interpretation ID: 2343y
Robert Bosch GmbH
Postfach 42
7410 Reutlingen
W. Germany
Dear Herr Spingler:
This is in reply to your FAX to Richard Van Iderstine of this agency, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.
Your first question is:
1) To turn the adjusting screws of a HB-2 headlamp it will be necessary to remove two snap on covers without the use of any tool. Will this be legal?
Section S7.7.2 requires a headlamp to be installed with a mounting and aiming mechanism that allows aim inspection and adjustment, "and is accessible for those uses without removal of any vehicle parts, except for protective covers removable without the use of tools." The section is not directed to the number of covers, only the ease of removal for the specified purposes. Therefore, the use of two snap on covers is not prohibited by Standard No. 108.
Your second question is:
2) A combination of HB2-headlight (low + high beam) and auxiliary driving beam in one unit shall be equipped with only vertical adjusting screws for the driving beam. The beam pattern will be so wide that even bulbs with extreme tolerances will allow to meet all photometric requirements without horizontal adjustment. Will this be legal?
Under section S7.7.2, the aiming mechanism of a headlamp must allow for adjustment of both horizontal and vertical aim. Thus, the portion of the lamp that provides the lower and upper beam must have both horizontal and vertical aiming screws, and the headlamp would not comply with S7.7.2 if either aiming screw is lacking. For that part of the same headlamp that is a driving beam and which is therefore not regulated by Standard No. l08, the manufacturer may provide any means of adjustment it wishes, as long as it does not impair the effectiveness of the aim of the upper and lower headlamp beam. Your final question is:
3) When will the 9007 bulb be legal? Date of final rule?
According to the plans of this agency, further action on the 9007 (proposed to be known as HB5) is expected in May l990.
I hope that this responds to your questions.
Sincerely,
Stephen P. Wood Acting Chief Counsel
/ref 108 d:3/23/90