Interpretation ID: nht88-3.47

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 12, 1988

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: M. IWASE -- MGR., TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 10-18-89 TO ERIKA Z. JONES FROM M. IWASE AND LETTER DATED 4-8-88 TO ERIKA Z. JONES FROM M. IWASE. TEXT:

This is in reply to your letter of April 8, 1988, with respect to the agency's proposed S7.7.5.2 of Standard No. 108, on-vehicle aiming requirements which would include a Vehicle Headlamp Aiming Device (VHAD). This was proposed on December 29, 1987, as Notice 5 to Docket 85-15.

You have asked whether two designs contemplated by Koito comply with the VHAD as proposed. With respect to the second design, "Structure-2", you requested that it be considered confidential as it involves a Koito idea related to a patent application. However, you withdrew that request on June 9, 1988.

With respect to your two designs, you appear to have understood that the agency's intent in the proposal was to provide broad parameters for VHADs to afford manufacturers design freedom in meeting the specifications. Under S7.7.5.2 it is the headlamp system that "includes" a VHAD, rather than "incorporates' it. Under subsection (b)(7) photometric testing is provided for "The VHAD and headlamp assembly (if the headlamp is separable or intended to be used with the VHAD)...." This means that the VHAD may be integral with the headlamp assembly, or separate from it (though presumably provided with the vehicle as part of its original equipment), as fits the manufacturer's design. Each of your designs complies with the intent of S7.7.5.2; however, I must emphasize that this is only a proposal, and the form of a final requirement, if any, has not been determined.

We have further comments about your devices. Structure 1 incorporates a stationary lens and housing, but the reflector is adjustable. The lamp must be designed to conform to the photometric requirements of Standard No. 108 with the reflector in any position within the proposed aimability range of +/- 4 degrees vertical and +/- 2 1/2 degrees horizontal, or any combination thereof. Structure 2 features a detachable spirit level which is inserted when the replaceable bulb is removed from the headlamp. Although the proposal does not specifically prohibit this feature, the test procedures do not anticipate a VHAD design where the light source would be removed and replaced with the VHAD.

I hope that this answers your question.