Interpretation ID: nht94-2.71

TYPE: Interpretation-NHTSA

DATE: May 6, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jeffrey D. Shetler -- Manager of Government Relations, Kawasaki Motors Corp. U.S.A.

TITLE: None

ATTACHMT: Attached to letter dated 2/7/94 from Jeffrey D. Shetler to the Associate Administrator for Enforcement, NHTSA (OCC-9697)

TEXT:

This is in reply to your letter of February 7, 1994, to the Associate Administrator for Enforcement requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108. So that we may serve you better in the future, please note that the Office of Chief Counsel is the one to which requests for interpretations should be addressed.

You have asked whether the "proposed application of a projector beam headlamp to a motorcycle" will meet the requirements of Standard No. 108. In this headlamp "the projector beam (lower beam) is located on the left side and the high beam is on the right side." You continue by saying that "the outer lens of the headlamp assembly is symmetrically positioned about the vertical centerline," and you ask whether the headlamp complies with the requirements of Table IV of Standard No. 108.

Table III of Standard No. 108 requires a motorcycle to have at least one headlamp. Table IV requires the headlamp to be located "on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline." The device you describe contains the upper and lower beams in one housing and hence is a single headlamp. Although your projector beam headlamp would be mounted literally on the vertical centerline, the beams provided by the headlamp are located on eit her side of the centerline and are therefore asymmetrical in relation to the centerline of the motorcycle when either beam is activated. A redesign of the lamp so that its vertical centerline becomes its horizontal centerline and Line A becomes the vert ical centerline would be a configuration that meets Table IV since both beams of the single headlamp would then be located on the vertical centerline. SAE J584 does not specify the location of one beam in relation to the other for dual beam motorcycle h eadlamps, i.e., whether one beam is to be mounted above or below the other.

Your second question concerns an interpretation of S5.1.1.23. This paragraph provides an alternative for motorcycles to the headlamps specified by Table III, and allows a motorcycle to be equipped with "one half of any headlighting system specified in S 7 which provides both a full upper beam and full lower beam, and where more than one lamp must be used, the lamps shall be mounted vertically, with the lower beam as high as practicable." You have asked whether this means that your proposed headlamp "sh all be mounted on the upper half and the high beam shall be on the lower half when using one half of any headlighting system specified in S7," or "is our proposed layout in the attachment acceptable?"

As I have explained, your proposed layout in the attachment is not acceptable under Table IV without reorientation. The headlighting systems specified in S7 are those intended for four-wheeled motor vehicles (other than trailers). As we understand it, your proposed headlamp has been developed as a headlamp system for motorcycles and not as half of a headlamp system for vehicles other than motorcycles. Because motorcycle photometrics differ from those for vehicle other than motorcycles, your proposed headlamp could not be half of a system specified in S7 which may be used on motorcycles as an alternative to the headlamps specified by Table III.