Interpretation ID: nht88-1.16
TYPE: INTERPRETATION-NHTSA
DATE: 01/14/88
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Nissan Research & Development, Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, Michigan 48104
Dear Mr. Maeda:
This is in reply to your letter of June 30, 1987, asking for an interpretation of paragraph 54.1.1.36(b)(3) of Motor Vehicle Safety Standard No. 108.
That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that "when the headlamp assembl y is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes." You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assemb ly "and by the headlamp when it is mounted on the vehicle."
SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicl e. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp.
I hope that this answers your question.
Sincerely,
Erika Z. Jones Chief Counsel
June 30, 1987 Ref: W-253-H
Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Room 5219 Washington, D.C. 20590
Dear Ms. Jones:
Nissan Research & Development, Inc., on behalf of Nissan Motor Company, Ltd. of Tokyo, Japan, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, "Lam ps, Reflective Devices and Associated Equipment."
Among its requirements, S4.1.1.36(b) (3) of Standard 108 stipulates that the replaceable bulb headlamp shall be designed to conform to Section 6.1 - "Aiming Adjustment Test" of SAE J580 AUG79, "Sealed Beam Headlamp Assembly.
Item 6.1.1 of the above-referenced "Aiming Adjustment Test" states that, "when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of + 4 deg. shall be provided in both the vertical and horizontal planes."
Nissan's question is whether this minimum aiming adjustment requirement is to be achieved:
1. by the headlamp assembly (by the component unit) itself, or
2. by both the headlamp assembly (as a component unit)
and by the headlamp when it is mounted on the
vehicle?
Erika Jones June 30, 1987 Page Two
Thank you very much for your assistance. Please contact Mr. Tomoyo Hayashi of my Washington staff at (202) 466-5284, if you have any questions or require further details. I would appreciate it if you would please also notify Mr. Hayashi when your respons e has been issued.
Sincerely,
Toshio Maeda Executive Vice President & Chief Operating Officer