Interpretation ID: nht94-4.16

TYPE: Interpretation-NHTSA

DATE: August 31, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Guy Dorleans -- Legal Compliance Department, Valeo Vision (France)

TITLE: None

ATTACHMT: Attached to letter dated 7/15/94 from Guy Dorleans to Office of Chief Council, NHTSA

TEXT:

We have received your letter of July 15, 1994, asking whether certain front lamp designs would be permissible under Federal Motor Vehicle Safety Standard No. 108.

In the basic front lamp design, the upper beam photometrics of Figure 17A would be provided by Lamps A and B. You have asked whether it is possible to add Lamp D, "an auxiliary driving beam." In this variation "all three A, B and D filaments would be p ermanently energized together in high beam mode and table 17a (sic) of FMVSS 108 is then fulfilled." Lamp D meets the photometric requirements of SAE Standard J581 JUN89 Auxiliary Driving Lamps.

The photometrics of Figure 17A apply to two-lamp integral beam or combination headlighting systems, and the design in your drawing is that of a four-lamp system, subject to the photometrics of Figure 15A. This configuration is not permissible under Stan dard NO. 108.