Interpretation ID: nht68-1.17

DATE: 04/30/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: JOSEPH LUCAS LIMITED

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 1, 1968, to the Deputy Director, National Highway Safety Bureau, concerning your interpretation of certain requirements of Motor Vehicle Safety Standard No. 108.

The installation requirements contained in the SAE Standards that are referenced in Standard No. 108 are enforceable requirements unless specifically excepted by Standard No. 108. With respect to the installation of license plate lamps, Standard No. 108 provides an exception to the "Installation Recommendations" contained in SAE Standard J587b, in that Standard No. 108 requires a location "at rear license plate." This exception permits installation of the lamp at the top, sides or bottom of the license plate, instead of top and sides only as specified by SAE installation recommendations.

With two exceptions, the lighting devices required by Standard No. 108 must use bulbs conforming to SAE Standard J573b and bulb sockets conforming to either SAE Standard J56b or SAE Standard J822. The two exceptions are (1) motorcycle headlamps conforming to SAE Standard J584, and (2) disposable (throw-away) type lamp assemblied (other than sealed-beam headlamps) that do not use sockets. Sealed-beam headlamps must conform to SAE Standard J567a and J580a which, in turn, require sealed units conforming to SAE Standards J567b or J822. The disposable type lamps ((2) above) are excepted from the requirements of SAE Standard J567b since thy are equipped with non-replaceable bulbs and electrical connectors rather than sockets. It is to be noted that Standard No. 108 is not applicable to motorcycles until January 1, 1969.

Sincerely,

The Administrator Federal Highway Administration U.S. Department of Transportation

For the attention of Deputy Director National Highway Safety Bureau

Dear Sir,

We wish to refer to U.S. Federal Standard 108 and two problems which we foresee in meeting the requirements.

1. Illumination of Licence Plates

We have been considering the implications of a recent report that the Federal Safety by Authorities are treating the 'Installation Recommendation' in S.A.E. J587b (Licence Plate Lamps) as an enforceable part of the Standard.

Since this paragraph is not part of the Test Specification, it is not wholly within our power to ensure compliance with it, since we cannot always be sure that a vehicle manufactures will locate a given number plate scheme in the attitude which we recommend. There is nothing to stop Adminvorrthing the whole scheme while continuing to comply with the photometric specification.

Thus, we are greatly concerned that a passage which is specifically stated to be a recommendation should be enforced. There has, up to the present, been no information to this effect. We have always understood that it is not the intention of the Society of Automotive Engineers that their recommendations should be enforced and that only when such a recommendation has been given a thorough trial may it then be made into a standard.

The Tail-lamp J585 and Turn-signal lamp J588 standards contain installation requirements. We should like to know if these are also being regarded as a part of the Standard and are being enforced.

2. Lamp Bulbs

There have also been indications that only those bulbs listed in S.A.E. Standard J573b will be acceptable under the new Federal Standard. The various S.A.E. standards for different functions of lamps all refer to Section C of S.A.E. standard J575 which in turn refers to standard J575b, but also states that where special bulbs are specified they should be submitted in with the devices and the same or similar bulbs should be used in the tests. The implication of this is that lamps not having bulbs fitted to them which comply with the S.A.E. standard could be submitted with samples of their own bulbs, and the lamps would be acceptable in this form.

The use of cartridge bulbs presents rather a special case since many of the signalling lamp standards (notably the back-up lamp standard J 595b) also call up the bulb-socket standard J 567, and the Federal Standard itself calls up the Recommended Practice J822, so that there is no provision for a suitable socket for the cartridge bulbs. This will therefore be the subject of a separate petition.

However, Motor-cycle headlamps are rather different. In this case no bulb socket standard is called up. We have always sent over motor-cycle headlamps fitted with bulbs with British pre-focus caps. The majority of British motor-cycles transmit too much vibration to the headlamps for sealed-beam units to be practical. If it is the intention to require that only bulbs listed in the S.A.E. standard shall be fitted to all motor vehicles, then a situation will arise where there will not be suitable headlamps available for British motor-cycles.

We submit the above points for consideration and would be pleased to know whether our interpretation of the Standard and whether the difficulties we anticipate are, in fact, real, and to know what line is ought to take in order to comply with the Standard.

Yours truly,

JOSEPH LUCAS (ELECTRICAL) LIMITED --

M.D. Prickett, Chief Engineer - Special Duties