Interpretation ID: nht87-1.54
TYPE: INTERPRETATION-NHTSA
DATE: 03/28/87
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: T. Chikada -- Manager, Automotive Lighting, Stanley Electric Co. Ltd.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. T. Chikada Manager, Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan
This is in reply to your letter of August 4, 1986, with respect to a new headlamp and aiming adaptor design. The lens of the headlamp will be tilted 60 degrees from vertical. Although this is too extreme an angle - for use of mechanical aimers for headla mps, you have developed an adaptor for use with the aimer whereby the new headlamp may be mechanically aimed. You have asked whether mechanical aim using the new adaptor is permissible.
Federal Motor Vehicle Safety Standard No. 108 does prescribe the types of aimers to be used with replaceable bulb headlamps, but not the adaptors. As you have noted, the standard does require such headlamps to be capable of mechanical aim by incorporatin g on the lens face three pads which meet the requirements of the Standard's Figure 4. You have informed us that your headlamp design complies with this requirement, and furthermore meets the photometric requirements of Standard No. 108.
However, there are some practical considerations that are important if you intend to market this headlamp. Although providing an aimer adaptor is not required by Standard 108, no adaptors for your unique lamp have been provided to service facilities. The only adaptors which exist today are those designed to accommodate sealed beam headlamps replaceable bulb headlamps with lens angles up to 50 degree for smaller lamps and 40 degrees for larger ones. Neither of these can accommodate the lamp you have prop osed.
In summary, the standard does not appear to preclude use of your new designs, and although not specifically required by the standard, an adaptor should be provided as original vehicle equipment since suitable adaptors do not exist in the service communit y.
Subsequent to August 4, we received your request for confidential treatment of the letter. We replied that it is our policy that substantive interpretations be made publicly available but informed you that we would be willing to delete all identifying re ferences to you and your company. You replied that this was agreeable to you. However, because this headlamp is the subject of SAE Technical paper 870064 Development of MR (Multi-Reflector Headlamp) and was discussed at SAE and was discussed at SAE meeti ngs in February 1987, Stanley has waived all considerations of confidentiality through its public disclosure of the matter. Consequently, this letter will be made publicly available.
Sincerely,
Erika Z. Jones Chief Counsel
September 4, 1986
Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.
Dear Ms. Jones,
We have asked you an advice about permissibility of mechanical aiming with the additional adaptor by the letter dated August 4, 1986.
As for the above mentioned letter, we would like to ask a favor of you. We would like you to deal with this matter in strict confidence.
Since this headlamp is being developed as our new idea for customer satisfaction, we are trying to keep this information inside of our company. Therefore we would like you to maintain the secrecy of this information strictly against any other third party .
Your kind cooperation will be highly appreciated and as well we are looking forward to your reply to our problem.
Sincerely yours,
Stanley Electric Co., Ltd.
T. Chikada Manager, Automotive Lighting Engineering Control Dept.