Interpretation ID: 7244
Suite 1200
140 Mayhew Way
Pleasant Hill, CA 94523
Dear Mr. Twyford:
This responds to your letter of April 21, 1992, to the Federal Highway Administration, which has been forwarded to this agency for reply.
You wish to complain "about some makes of new cars that have two sets of headlights (4) which operate at the same time." If this agency plans to do nothing about it, you "plan to take this matter up with Congressmen and U.S. Senators."
You are not alone in your concern about headlamp glare created by new motor vehicles. Other citizens have brought the subject to the attention of Members of Congress. I enclose a copy of a recent letter from the Deputy Administrator of this agency to Senator Cohen of Maine which is representative of our views on this issue. You will see that a number of factors may be responsible for creating a perception of glare. We note that you have already been in touch with the Department of California Highway Patrol, and that California has no periodic motor vehicle inspection.
With respect to the specific comments in your letter, the agency does not "approve" specific headlamp designs. Standard No. 108 sets forth photometric performance requirements to be met on both the upper and lower beam, and does establish maximum limitations at some of the photometric test points. Further, in a four-headlamp system, the upper and lower beams may be provided by all headlamps. Headlamp manufacturers must ensure that their products meet these requirements, and certify that each headlamp complies by placing a "DOT" mark on the lamp. There is no requirement that a manufacturer obtain permission from this agency before introducing the lamps into the market.
We appreciate your concern.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosure ref:108 d:5/14/92