Interpretation ID: nht90-3.70

TYPE: Interpretation-NHTSA

DATE: August 30, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: S. Watanabe -- General Manager, Automotive Equipment Technical Coordination Dept., Stanley Electric Co., Ltd.

TITLE: None

ATTACHMT: Letter dated 8-2-90 to R. L. Van Iderstine from S. Watanabe; (OCC 5094)

TEXT:

This is in reply to your letter of August 2, to Mr. Van Iderstine of this agency asking for an interpretation of Motor Vehicle Safety Standard No. 108. Although rulemaking notices provide the name of a NHTSA staff engineer, such as that of Mr. Van Iders tine, to contact for further information, correspondence asking for interpretations of the Federal motor vehicle safety standards should be addressed to the Chief counsel.

It is your understanding that as of September 1, 1990, "lamp manufacturers such as Stanley, not car manufacturer) have to manufacture the external mechanical aiming of replaceable bulb headlamps which conform to the downward torque deflection requirement s." You ask for confirmation of your understanding.

Your understanding is correct. The last sentence of Section S7.7.5.1(a) of Standard No. 108 states that "Each headlamp system that is designed to conform to paragraph S7.5 and that is designed to use such external aiming devices, and which is manufactur ed on or after September 1, 1990, shall comply with the downward torque deflection requirements of S7.7.5.1(a). Because it is the headlamp system that must comply with the requirement, it is the manufacturer of such system that is required to comply on a nd after September 1, 1990.

As you appear to understand, vehicle manufacturers need not equip their vehicles with the new systems on September 1, 1990, and may continue to manufacture vehicles with the old systems until their inventory is exhausted.