Interpretation ID: nht90-4.83

TYPE: Interpretation-NHTSA

DATE: December 13, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: M. Iwase -- General Manager, Technical Administration Department, Koito Mfg. Co. Ltd.

TITLE: None

ATTACHMT: Attached to letter dated 11-20-90 to Paul Jackson Rice from M. Iwase (OCC 5458)

TEXT:

This is in response to your letter of November 20, 1990 with respect to "interpretation and/or petition" concerning combination headlighting systems.

Koito has asked about the permissibility of two or four lamp headlighting systems in which the upper beam would be provided by integral beam headlamps, and the lower beam by replaceable bulb headlamps.

The systems you describe would not be permissible under Standard No. 108, which allows only the three types of headlighting systems that you mention. Integral beam headlighting systems must be comprised of integral beam headlamps which, by definition, a re headlamps other than sealed beam or replaceable bulb headlamps. Replaceable bulb headlighting systems are those that incorporate the standardized replaceable light sources listed in Standard No. 108.

We are transmitting your request to the Office of Rulemaking, for consideration as a petition for rulemaking.