Interpretation ID: nht88-2.46

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/88

FROM: L. F. ROLLIN COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TO: JERRY K. YOST -- JERRY'S SERVICE

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DOUGLAS H BOSCO, FROM ERIKA Z JONES, REDBOOK A32 (2) STANDARD 108; LETTER DATED 06/16/88, TO ERIKA Z. JONES, FROM DOUGLAS H. BOSCO; LETTER DATED 08/03/87 TO DOUGLAS H. BOSCO FROM ERIKA Z. JONES; LETTER DATED 03/28/88 TO C-MORE-LITE JERRYS SERVICE FROM DON O. HORNING RE TEST REPORT NO 92606; 1988 LETTER TO ERIKA Z. JONES FROM JERRY'S SERVICE

TEXT: Dear Mr. Yost:

This letter is in response to your inquiry about the legality of the C-More-Light headlight device.

My engineering staff reviewed your letter, the letter from NHTSA and the test report (#92606) from Industrial Testing Laboratories (ITL). It is our opinion that the device is legal to install and use on any headlight system designed to meet type "F" pho tometrics. This system is also permitted by California law as long as the photometric output is within the standards established for any other type of headlight. The ITL tests appear to show compliance.

Vehicles equipped with the C-More-Light and a control group of similar vehicles without the C-More-Light device should be used in field testing. Responses from drivers should address the effectiveness of the headlights on both high and low beam as well as the reactions of approaching drivers. Reactions such as flashing high beams or other indicators that the headlights are annoying should be noted. Effective testing should ensure that the test and control group vehicles have properly adjusted headlig hts and that the driver's responses are not prejudiced (not informing the drivers which vehicles have operational C-More-Light devices). We look forward to seeing a report on your test results.

Any further questions should be directed to my engineering staff.

Very truly yours,