Interpretation ID: 2903yy
Corporate Manager
Toyota Motor Corporate Services
of North America, Inc.
1850 M Street, N.W.
Washington, D.C. 20036
Dear Mr. Inui:
This responds to your letter of February 20, 1991, with respect to an interpretation of Standard No. 108 as it relates to High Intensity Discharge Headlamp (HID) designs contemplated by Toyota. You explained these designs in greater detail to NHTSA staff members in a meeting with them on February 20.
Standard No. l08 defines an "integral beam headlamp" as one which is neither a sealed beam headlamp nor one equipped with a standardized replaceable light source, but one which is a "headlamp comprising an integral and indivisible optical assembly, including lens, reflector, and light source." You have presented two HID headlamp designs, and have asked whether these lamps are "integral beam headlamps" as defined by Standard No. 108.
These lamps differ from conventional headlamps by having ballast, consisting of a "starter" affixed to the rear of the headlamp, connected to a "converter," which is separated from the headlamp-starter unit. Because of space limitations, it may not be feasible to integrate the ballast into the headlamp enclosure. On one of these headlamps (Figure 2) the starter and converter are directly connected to each other by a "hard wire" while in the other (Figure 3), the starter and converter are connected by "hard wires" that meet at a connector between the two. In this design, the ballast units would be installed separately, then permanently joined by a connector, which could not be separated without destroying the connector. You believe that both designs are "integral beam headlamps."
The phrase "optical assembly" in the definition of "integral beam headlamp", in our view, encompasses all lamp components other than the power source which are required for illumination of the headlamp. This means that an "optical assembly" includes the ballast. Although the lamp, starter, and converter may be permanently attached to each other, and could be considered "indivisible," and the starter could be considered to be "integral" with the lamp body, the positioning of the converter at some distance from the starter, as shown in your Figure 2 and Figure 3, does not render it "integral" within the meaning of the definition, unless it is permanently attached to the starter.
However, a design which had a connector as in your Figure 3 and described in your letter, would be considered both "integral" and "indivisible" if its individual components were not permanently attached to each other until the installation of the device in a motor vehicle, providing that any portion of the device could not be subsequently detached without damage sufficient that the entire device would have to be replaced. This would apply to either original or replacement equipment.
Sincerely,
Paul Jackson Rice Chief Counsel /ref:l08 d:3/25/9l