Interpretation ID: 86-1.41

TYPE: INTERPRETATION-NHTSA

DATE: 02/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Yoshikazu Ito

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Yoshikazu Ito Manager, Operations Sect. Overseas Operations Dept. Tokai Rika Co. Ltd. Oguchi-cho Aichi Pref. 480-01 JAPAN

Dear Mr. Ito:

This is in reply to your letter of November 29. 1985, to Jeffrey R. Miller, former chief counsel of this agency, with reference to the acceptability of a headlamp switch under Federal Motor Vehicle Safety Standard No. 108. According to you, "upper and lower lamps light at the same time when a driver puts on the switch for headlamp horn in a daytime with light switch OFF...."

You have asked whether the circuit complies with Standard No. 108 and any SAE standards referenced in Standard No. 108. Standard No. 108 does not specify circuit design. The "optical horn" is neither required nor prohibited by Standard No. 108 and is viewed as permissible for its use for momentary signalling purposes. This would include simultaneous activation of both upper and lower beam filaments as in your design.

I believe that this uppers your other questions as well.

Sincerely,

Erika Z. Jones Chief Counsel

November 29, 1985

Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration US Department of Transportation 400 Seventh Street. S.W. Washington. D.C. 20590 U.S.A.

Re: Head Lamp Switch Circuit

Dear Sir:

We are automotive switch manufacturer in Japan and are making prototype of a head lamp switch for our customer's new car model for U.S.A. which has a circuit by which upper and lower lamps light at the same time when a driver puts on the switch for head lamp horn in a daytime with light switch OFF (please see an attached sheet). To our experience, the circuit has never been designed for cars which are to be marketed in U.S.A.

Would you like to answer the following questions?

1. Does the above-mentioned circuit comply with requirements of FMVSS and the concerned standards (SAE?) referred in FMVSSS:

2. What provision(s) of FMVSS and the standards involve this matter?

3. What are interpretation of the FMVSS and the standards provision(s)?

We really appreciate it if you could kindly send us your answers by December 27, 1985. Your kind assistances have been useful for us all the time.

Thank you for your assistance in advance.

Faithfully yours,

TOKAI RIKA CO., LTD.

Yoshikazu Ito, Manager Technical Operations Sect. Overseas Operations Dept.