Interpretation ID: nht78-2.10
DATE: 11/29/78
FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA
TO: Ichikoh Industries, Ltd.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of September 22, 1978, to Bill Eason of our Office of Rulemaking asking several questions about motor vehicle headlamps and the amendment to Motor Vehicle Safety Standard No. 108 issued on July 27, 1978.
Your questions and our answers are:
1. Ichikoh headlamps are designed to comply with SAE Standard J579c with maximum candela not exceeding 37,500. Does the amendment allow Ichikoh to place "DOT" and the new designation code on the lens of each headlight?
Ichikoh's practice reflects compliance with the option afforded by S4.1.1.33 until July 27, 1978. The deletion of the option has the effect of allowing the higher maximum candlepower permitted by J579c but does not require it. Thus, Ichikoh may continue its existing practice under the amendment. One purpose of the marking code, however, is to enable a consumer to replace original equipment headlamps with lamps of compatible photometric output. Currently, S4.1.1.21 as amended requires the lens of each Ichikoh headlamp designed to conform to J579c to be marked with the new code on and after July 1, 1979. Obviously such a marking will be misleading if, even though designed to conform to J579c, a headlamp's maximum candela does not exceed 37,500. Accordingly, we are reviewing this problem with the idea of proposing rulemaking that would delete the code requirement for all headlamps whose maximum candela does not exceed 37,500. We do not anticipate a change in the requirement of S4.1.1.21 that the lens of each J579c headlamp be marked with the "DOT" symbol since Ichikoh headlamps comply with J579c, even if they do not take advantage of the now-permissible maximum.
2. With reference to your quality control system, will the headlamps "be allowed to exceed 37,500 cd without any modification of the light source (filament) and wattage?"
I am not quite sure what you mean. If you are asking whether Ichikoh may relax quality control so that an occasional headlamp may exceed 37,500 cd the answer is yes. Headlamps designed to J579c are not restricted to the maximum imposed by J579a.
3. You ask our comments on possible mismatch of headlamps on the same vehicle, i.e., one low intensity headlamp and one high intensity headlamp.
NHTSA is concerned about this possibility and, as indicated in reply to your first question, is considering rulemaking to delete the code requirement for low intensity J579c headlamps. Your second question, however, does raise the issue of identification of headlamps whose candela may exceed 37,500 but whose maxima are far less than 75,000. We shall also consider this issue and may issue a consumer bulletin advocating replacement of headlamps in pairs to help resolve this potential problem.
4. You ask whether NHTSA intends to adopt the concept of ECE Regulation No. 20 in the near future. This Regulation requires a mark on a headlamp lens indicating candlepower grade.
The NHTSA does not plan to adopt the requirements of Regulation No. 20 because this regulation is in essence an indicator of quality control.
I hope this answers your questions.
SINCERELY,
ICHIKOH INDUSTRIES, LTD.
ISEHARA-PLANT
September 22, 1978
Bill Eason Office of Rulemaking National Highway Traffic Safety Administration U.S. DEPARTMENT OF TRANSPORTATION
Subject: Motor Vehicle Headlamps
We, Ichikoh Industries, Ltd., are an original equipment manufacturer of sealed beam headlamps, signalling lamps, rear view mirrors and other accessories for motor vehicles.
With regard to the recent amendment of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, Docket No. 78-5 : Notice 3, issued on July 27, 1978, we would like to confirm you the following matters:
1. All our sealed beam headlamps (circular and rectangular types) have been approved in each States including AAMVA compliance with the applicable (photometric) requirements of FMVSS 108 : that is, SAE Standard J579c.
At the present, the maximum candlepower of each headlamp is maintained as not exceed 37,500 cd, and we have no intention changing to the higher wattage allowed in the above new amendment.
In such a case: Does it permit to indicate "DOT" and new "designation code" defined in new paragraph S4.1.1.21 on each lenses of our headlamps?, and
2. May we interpret that, by the new amendment, the old requirements of the maximum candlepower 37,500 cd to headlamps will be allowed to exceed 37,500 cd without any modification of the light source (filament) and wattage?
This problem concerns to our quality control system.
3. Besides, according to the amended regulation, it can not install both headlamps compliance with SAE J579a and J579c on one (1) vehicle.
However, if the above item No. 1 is accepted, it result in allowing to use the different type headlamps with the same code on a vehicle, that is, the lower candlepower headlamp(s) (not more than 37,500 cd) and the higher candlepower headlamp(s) not more than 75,000cd.
This means headlamp users can not select such different type headlamps with the same identification code, and such mixed use of headlamps would give rise to undesirable influence on the visibilities for road users.
Besides, it would lead to substantially allow the use of both headlamps compliance with SAE J579a and J579c on a vehicle.
We would like to hear your view point on this problem.
4. As you well know, ECE Regulation No. 20, Halogen Headlamps, requires to mark on each headlamp lens severally graded identification indicating the reference of the maximum candlepower. This make easy to know the headlamp grade.
On the other hand, it is impossible to know the headlamp grade (candlepower) with the identification code on the lens under the amended regulation of FMVSS 108.
Do you have the intention to adopt the conception of ECE Regulation No. 20 in the near future?
With regard to the above matters, your kind and early reply would be highly appreciated.
Suminori EGUCHI, Chief Engineer Technical Department.