Interpretation ID: nht78-4.11

DATE: 10/31/78

FROM: AUTHOR UNAVAILABLE; S. P. Wood for J. J. Levin, Jr.; NHTSA

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 6, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the "N" dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.

You further advised that the proposed design would not interfere with the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.

Since Figure 8(B) of SAE J571d shows that the "K" dimension shall not exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.

SINCERELY,

TOYOTA MOTOR SALES, U.S.A., INC.

September 6, 1978

Joseph Levin Office of the Chief Council NHTSA

RE: Interpretation Request of FMVSS 108

Dear Mr. Levin:

This is to request your interpretation of SAE J 571d with regard to the retaining ring for 4 x 6 1/2 inch rectangular headlamps, as quoted in FMVSS 108, "Lamps, Reflective Devices, and Associated Equipment."

According to Fig. 8 (B) of SAE J 571d, the forward portion of the retaining ring from the lens surface is limited to 1.52mm ("K" MAX). However, we feel that as long as the performance requirements specified in SAE J 580 a and b, and the aiming requirements specified in SAE J 602c are conformed (Illegible Word), it is not necessary to restrict "K" MAX to 1.52mm.

We are planning to introduce some models with 4 x 6 1/2 inch rectangular headlamps in the near future. The retaining ring is extended ahead, and is formed into a part of the ornamental door or bezel. (See attached drawing.) This retaining ring, as illustrated, is designed so that the opening dimension "L" must comply with the dimension required by the applicable SAE J 571d, "Dimensional Specifications for Sealed Beam Headlamp Unit." The ring's frame portion "M," which is relatively wider in flatness, as indicated, is made to be securely fitted with an aimer specified in SAE J 602c, "Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Unit," when the headlamps are mechanically aimed.

This headlamp housing can fully comply with the requirements of functional performance (such as headlamp aiming adjustment, vibration resistance, and so on) specified in the applicable SAE J 580 a and b, "Sealed Beam Headlamp assembly," as referred to in the current FMVSS No. 108.

We would appreciate your interpretation of this information at your earliest possible convenience.

TOYOTA MOTOR SALES, U.S.A., INC.

M. YANADA for J. Kawano Director/General Manager Factory Representative Office

cc: M. V. ELLIOTT, OFC. OF VEHICLE SAFETY STANDARDS, NHTSA

Attached Drawing

4 x 6 1/2 in. Rectangular Headlamp Retaining Ring

(Dimension: mm)

Retaining ring extended to a part of ornamental bezel

Note: "L": 92.98 +/- 1.30X133.42 +/- 1.30 (SAE required dimension)

(Graphics omitted)