Interpretation ID: nht88-3.10

TYPE: INTERPRETATION-NHTSA

DATE: 08/19/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: DOUGLAS H. BOSCO -- HOUSE OF REPRESENTATIVES

TITLE: NONE

ATTACHMT: 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 06/09/88 TO JERRY K. YOST FROM L. F ROLLIN; LETTER DATED 03/28/88 TO C-MORE-LITE JERRYS SERVICE FROM DO N O. HORNING RE TEST REPORT NO 92606; 1988 LETTER TO ERIKA Z. JONES FROM JERRY SERVICE

TEXT: Dear Mr. Bosco:

This is in reply to your letter of June 16, 1988, with reference to your constituent Jerry Yost of Occidental. Thank you for enclosing our previous correspondence on Mr. Yost's C-More Light invention. This device is a relay which would allow a headlamp 's lower beam to remain in operation when the upper beam is activated. In my reply of August 3, 1987, I advised you that the Federal motor vehicle lighting standard explicitly prohibits simultaneous activation of upper and lower beams in four-lamp headl ighting systems other than the one we call Type F (S4.5.8 of 49 CFR 571.108 Motor Vehicle Safety Standard No. 108). I explained that our historical concern has been that the maximum candlepower limitations of the Federal standard might be exceeded.

In your latest letter, you have enclosed a copy of a test report by Industrial Testing Laboratories and a letter from the California Highway Patrol. You have asked the steps, if any, that Mr. Yost should take to market legally his device. The test repor t is intended to show that maximum candela will not be exceeded when the device is used in a four-lamp headlamp system. California advised that the device appeared legal to install on vehicles equipped with Type F headlamp systems, and that "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".

We have reviewed the ITL test report, and find it indicative of the features and limitations of Mr. Yost's system. The test report shows a failure of the dual filament 2A1 lamp (second column from the left) at test point 4D-V where 3490 candlepower is m easured. Note the maximum limitation of 2500 candlepower at that test point (third column from the right, same line). Contrasted with this is an unusually low reading of 2540 candlepower for the same test point with the single filament 1A1 lamp (third column from the left) when up to 5000 candela is allowed (fourth column from the right). The net result, however, is that the combined maximum of 6030 candlepower (fourth column from the left) is well within the allowable 7500 maximum of Standard No. 10 8 (first column from the right). In essence, the test report indicates that the light at

2 test point 4D-V produced by the system under test does not achieve the balance contemplated by the standard, although the light at other test points meets the requirements of the standard.

While the test report indicates that a system using the lamps tested might conform to Standard No. 108, this was achieved by using what appear to be two lamps of moderate performance. The agency believes it likely that replacement headlamps for such a s ystem would more likely approach the maxima prescribed for 4D-V and other test points for Type 1A1 and 2A1 headlamps with the result that simultaneous operation of upper and lower beams would exceed the established limits. In other words, although an or iginal equipment headlighting system using the relay might meet Federal photometric specifications, there is no assurance that replacement lights would. Type F systems have been designed to preclude exceeding the maxima. Thus, our concern remains for l ighting systems using lamps other than Type F. The agency's views on simultaneous operation are discussed in further detail in a Federal Register notice published in 1986, a copy of which I enclose (Docket No. 81-11; Notice 14).

As I indicated before Mr. Yost's device may be legally installed as original or aftermarket equipment on any passenger car equipped with a Type F headlamp system. Use with any other original equipment headlighting system is expressly prohibited by Stand ard No. 108. As for aftermarket applications other than Type F, he should be aware of the statutory section (15 USC 13979(a)(2)(A)) prohibiting manufacturers, distributors, dealers, and motor vehicle repair businesses from rendering inoperative, in whol e or in part, any equipment installed in accordance with a safety standard if installation of the relay would result in a noncompliance with Standard No. 108.

We are providing a copy of this letter to the California Highway Patrol so that it may be aware of our views on this subject.

Mr. Yost and the agency share a common desire to improve foreground lighting, a subject currently under study at NHTSA. We appreciate his interest in motor vehicle safety.

ENCLOSURE

Sincerely,