Interpretation ID: nht92-9.35

DATE: January 29, 1992

FROM: J. Yoshimoto -- Manager, Technical Administration Dept., Koito Manufacturing Co., Ltd.

TO: James G. White -- Surface Group, Transport Canada

TITLE: Subject: CMVSS 108 "Lighting Equipment"; Reference: Canada Gazette Part II, Vol. 125, No. 26 dated December 18, 1991

ATTACHMT: Attached to letter dated 3/5/92 from Paul Jackson Rice to James G. White (A39; Std. 108)

TEXT:

Thank you for your kind consideration which you have always extended to us through SAE meeting.

We have studied the amended CMVSS 108 "Lighting Equipment" by Canada Gazette Part II Vol. 125, No. 26 dated December 18, 1991. And we would ask for your kind interpretation about "O" Mark on vertical/horizontal aim indicator of integral headlamp aiming device, specified in paragraph 108(28)(b)(ii)(A) and 108(28)(c)(ii)(A).

108(28)(b)(ii) a scale that has (A) a "O" mark that represents the vertical aim of zero degrees, ----------. 108(28)(c)(ii) a scale that has (A) a "O" mark that (I) presents the horizontal aim of zero-degrees ----------.

For these descriptions, it is unclear for us whether a mark of figure "O" be literally required for indicating zero degrees on vertical/horizontal aim indicator, or not.

In FMVSS 108 (U.S.), vertical/horizontal aim indicator of integral headlamp aiming device is required to have a zero mark, which does not necessarily mean a mark of figure "O", but may be just a reference mark. (Please refer to the attached copy of FMVSS 108 S7.7.5.2(a)(1) and (2).

Size of indicator is so small, that there is no space to add a figure "O" on it. Moreover, from the viewpoint of harmonization to FMVSS 108, CMVSS 108 should not require a figure "O" on the indicator, we think.

We would greatly appreciate if you would give us your kind interpretation to the above matter.

Thanking you for your kind and prompt reply in anticipation, we remain, With best regards.