Interpretation ID: nht90-4.82

TYPE: Interpretation-NHTSA

DATE: December 13, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: M.J.P. Ravier -- R&D Director, Valeo

TITLE: Re Your ref 861 M 90

ATTACHMT: Attached to letter dated 7-13-90 to P.J. Rice from J.P. Ravier and Guy Dorleans (OCC 5304); Also attached to letter dated 7-30-90 to J.P. Ravier from Kathleen Demeter

TEXT:

This is in further reply to your letter of July 13, 1990, with respect to whether your "Aiming concept for headlamps, Solution 2" is acceptable under paragraph S7.7.5.2 On-vehicle aiming of Federal Motor Vehicle Safety Standard No. 108. Ms. DeMeter of t his Office has previously addressed your request for confidentiality.

The headlamp aiming concept consists of a spirit level affixed to the reflector, and has its axis parallel to the longitudinal axis of the vehicle. Correct vertical aim is accomplished by ensuring that the bubble in the spirit level is centered at zero. Correct horizontal aim is ensured through a coaxial screw and nut with markings which align with markings on the vehicle body. The system bears graduations that accord with those imposed by S7.7.5.2.

As Valeo was informed when the device was demonstrated to members of this agency on June 29, 1990, the concept is an acceptable vehicle headlamp aiming device under S7.7.5.2. It is designed to meet the vertical aim requirements of S7.7.5.2(a)(1) and the horizontal aim requirements of (a)(2). We are pleased to provide a confirmation in writing.