Interpretation ID: nht89-2.38

TYPE: INTERPRETATION-NHTSA

DATE: 07/21/89

FROM: STEPHEN P. WOOD -- NHTSA

TO: Anonymous (confidential)

TITLE: NONE

TEXT: Dear

This is in reply to your letter of June 30, 1989, to John Donaldson of this Office titled "Request for Interpretation", submitted on behalf of your client. You request "that all identifying references to myself, my firm and [my client] in this letter and the responsive letter of interpretation" be deleted. Your request is granted on the basis that it relates to confidential business information and may be withheld under applicable Departmental regulations, 49 CFR Part 512.

You describe a lamp system as follows:

"The product is a headlamp consisting of a plastic lens and reflector, arc tubes (two each for high and low beam) and electronics for instant start and re-start of the headlamps as well as management of the operating current. A 12 volt connection is supplied for connection of vehicle line voltage".

You have asked for a letter "confirming" that this lamp system is designed to conform to the integral beam headlamp requirements of paragraph S7.4 of Federal Motor Vehicle Safety Standard No. 108, "subject only to compliance with the appropriate photomet ric requirements of FMVSS 108."

A headlighting system of the nature described must be designed to conform to all the pertinent requirements of S5.5, S7.1, S7.2, and S7.7, as well as S7.4, including mechanical aim and environmental requirements. However, since this headlamp does not us e filaments for converting the electrical energy to light energy, certain configurations of such systems may not conform, because some requirements are predicated upon the existence of filaments (e.g., S5.5.9 and S7.4(f)). If the headlamp you describe m eets all requirements, then it would appear to be an integral beam headlighting system designed to conform to S7.4. Whether the headlamp in fact meets those requirements is for the lamp manufacturer to determine, as it must assure the manufacturer of the vehicle on which it

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is installed that he may certify compliance of the vehicle with Standard No. 108. Further, the headlamp manufacturer itself must certify compliance of replacement equipment. If the headlamp is incompatible with these requirements and cannot meet them, then it would not appear to be an integral beam system. In that case, rulemaking would be required to accommodate it within the framework of Standard No. 108.

Sincerely,