Interpretation ID: 23723.ztv

Shigeyoshi Aihara, Project Manager
Regulation and Compliance
Ichikoh Industries, Ltd.
80 Itado Isehara-City
Kanagawa-Pref.
259-1192 Japan

Dear Mr. Aihara:

This is in reply to your letter of October 24, 2001, to Taylor Vinson of this Office, presented at the conclusion of a meeting in our offices that day with representatives of this agency. You supplemented the letter with an e-mail of October 29, 2001, to Richard Van Iderstine of the Office of Safety Performance Standards.

You have asked a question with reference to the definition of "replaceable bulb headlamp" that appears in Federal Motor Vehicle Safety Standard No. 108. In pertinent part, S4 of Standard No. 108 defines a replaceable bulb headlamp as a "headlamp comprising a bonded lens and reflector assembly."

Ichikoh has designed a headlamp with a lens and reflector assembly "fixed with synthetic rubber hot melt, clips, screws, and clamps." Although the "lens is separate from" the reflector, your letter stated that it cannot be removed from the reflector assembly "unless clamps (10 portions) are broken." You state that "when a lens is damaged, it will be exchanged by the whole lamp assembly," and assure us that the lens cannot be removed without destroying the housing. However, you confirmed that the headlamp can be reassembled using the screws provided, and that the housing is not destroyed, only damaged to the extent that all the features that hold the lens are not present. You have asked whether this configuration is sufficient to comprise "a bonded lens and reflector assembly."

We have provided only four interpretations of this phrase. On July 13, 1987, we informed Dr. Ernst of Hella that a design in which the lens was joined to the reflector by three screws did not constitute "a bonded lens and reflector assembly." On December 24, 1990, we informed Herr Spingler of Bosch that if a lens could not be manually separated from the housing, we would consider the bond sufficient for purposes of defining "replaceable bulb headlamp. On March 8, 1995, we again wrote Herr Spingler, on this subject, informing him that "the intent of the definition was that the lens and reflector assembly be an indivisible unit upon manufacture of the headlamp." This meant that, "if a lens is broken, the entire lens reflector assembly must be replaced." Finally, on September 11, 1998, we responded to Mr. Muraoka of Koito with respect to a headlamp "whose lens is bonded not with one adhesive agent, but with using some screws or clamps." We informed Koito that its design would not be a replaceable bulb headlamp because the connection was divisible and impermanent.

In the Ichikoh design under discussion, the lens is fixed to the housing by ten clamps, two clips, and screws. If a lens is broken, you initially informed us that the entire headlamp assembly would have to be replaced, since the lens could not be removed without breaking the clamps. However, it appears from subsequent discussions that the design of this headlamp is such that the lens can be replaced using the screws, even though the clamps are broken. This, in essence, is the interpretation we provided Dr. Ernst in 1987 when we said that a lens held by three screws was not a bonded assembly. Also, the synthethic rubber hot melt serves not as a bonding agent but as a gasket, in a manner similar to an O-ring in the Ernst lamp. Thus, the Ichikoh design does not comprise a "bonded lens and reflector assembly" for the purpose of defining a "replaceable bulb headlamp."

Your letter depicts four alternative designs, and you have described two more in your e-mail. Each of these alternatives utilizes the same clip and clamp arrangement as the original design, and a variation of the screw design intended to make the screw less accessible. Although the intent is to make it less likely that the lens will be replaced separately, in no case is it impossible to do so. Therefore, none of Ichikoh's alternatives comprise a "bonded lens and reflector assembly."

As we informed Herr Spingler in 1990, "the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable," and that "any method of adhesion that accomplishes this would be a sufficient bond." In view of our interpretations over the years, it is likely that only an adhesive agent will provide a bond that satisfies the definition.

Sincerely,

John Womack
Acting Chief Counsel

Enclosures
Ref:108
d.12/11/01