Interpretation ID: nht79-1.34
DATE: 11/09/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: SEV Corporation
TITLE: FMVSS INTERPRETATION
TEXT:
NOV 9 1979
Mr. H. J. T. Young Vice president - Technical Affairs SEV Corporation 33201 Harper Avenue St. Clair Shores, Michigan 48082
Dear Mr. Young:
This is in reply to your letter of September 24, 1979, to Mr. Vinson of this office in which you requested an interpretation of S4.1.1.19 of Federal Motor Vehicle Safety Standard No. 108.
S4.1.1.19 states:
A lamp manufactured on or after January 1, 1974 and designed to use a type of bulb that has not been assigned a mean spherical candlepower rating by its manufacturer and is not listed in SAE Standard J573d "Lamp Bulbs and Sealed Units", December 1968, shall meet the applicable requirements of this standard when used with any bulb of the type specified by the lamp manufacturer, operated at the bulb's design voltage. A lamp that contains a sealed-in bulb shall meet these requirements with the bulb operated at the bulb's design voltage.
It is noted that this paragraph consists of two sentences. You have asked whether the "lamp" and "bulb" of the second sentence are the same "lamp" and "bulb" of the first sentence.
The answer is no. The first sentence would require testing, at the bulb's design voltage, of bulbs used in sealed beam headlamps but not of bulbs used in, for example, taillamps; the former, though listed in J573d (Table 2), is not assigned a mean spherical candlepower rating since these bulbs emit shaped beams while the latter are both listed in J573d and have assigned mean spherical candlepower ratings. However, if the latter is used in the sealed lamp, it is tested at the bulb's design voltage rather than using the rated mean spherical candlepower. Furthermore, the rulemaking history of the paragraph clearly indicates that the two requirements are separate. As the agency noted in the preamble to the proposal, "The proposal specifies that when no rating has been assigned by the bulb manufacturer or the SAE or if the lamp is sealed and the bulb cannot be replaced, the bulb shall be operated at design voltage" (emphasis supplied) (38 FR 16230).
You noted that your question relates to the voltage required by Standard No. 108 for the photometric testing of a sealed beam headlamp that utilizes a European halogen bulb that meets ECE Regulation 37.
Since J579c requires the test voltage to be 12.8 volts for all the sealed beam bulbs, the photometric tests should be at 12.8 volts and not at the so-called "system voltage" of 12 volts.
I hope this is responsive to your request.
Sincerely,
Frank Berndt Chief Counsel
Mr. Taylor Vinson Office of the Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street S W WASHINGTON DC 20590 September 24 1979
Dear Mr Vinson
Request for Interpretation
With reference to S4.1.1.19 of FMVSS 108, are the "lamp" and "bulb" of the second sentence the same as these two items referred to in the first sentence, that is to say, is the bulb of the second sentence one to which the two conditions attaching to the bulb of the first sentence also apply?
This question relates to the voltage required by FMVSS 108 for the photometric testing of a sealed beam headlamp that comprises, in part, a "sealed-in bulb" that is an H1, H2, H3 or H4 halogen bulb that bears the E-mark signifying that it is in compliance with E/ECE/TRANS/505/rev.1/Add.36 Regulation 37 of the Geneva Agreement of 20 March 1958 as adopted by the several European governments. Yours sincerely
H J T YOUNG Vice President - Technical Affairs