The big rewrite
Feb 1, 2008 12:00 PM, BY RICK WEBER
In addition, this document amends 49 CFR Part 564, Replaceable Light Source Information, by adding a newly created Appendix C, which relocates figures addressing sealed beam headlamps that currently reside in FMVSS 108 and a relevant SAE standard there.
“We believe few lighting manufacturers still produce sealed beam headlamps, and their diminishing use is unlikely to draw new manufacturers of this type of lamp. Accordingly, we see no drawbacks to consolidating the information regarding sealed beam light sources with other light source information currently located in 49 CFR Part 564,” NHTSA says in the document.
The reaction from various industry associations:
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Jim Tipka, vice president of engineering for the American Trucking Associations (ATA): “We saw the rule as just being a reorganization of existing information and didn't see how it would have any ill effects on motor carriers or our members. Now it's a longer rule, but it seems to be a better packaging job. In the re-write, they tried to get all the extra references — like SAE diagrams — and incorporate them into the rule. So it, in theory, should be easier to use. That's the intent of the rule. Hopefully, it will work that way.”
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Jeff Sims, engineering manager for the Truck Trailer Manufacturers Association (TTMA): “It's very well-organized this time. It came out more user friendly. They pulled in a few interpretation letters, which will help. We were already using those interpretation letters, so I don't see any change for us. It might have an impact for a new trailer manufacturer. For someone who wanted to start a new business, it'd be easier for them to read and understand.”
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Bob Clarke, president of the Truck Manufacturers Association (TMA): “It was not to have been a substantive rule change. With that in mind, we didn't pay a huge amount of attention at the truck OE level. For our friends who supply lights, if there is a slight change in the way the photometric tests need to be run, that would just be taken into account when they do their certification work.”
A pioneering standard
Van Riper says FMVSS 108 dates back to the early 1960s and is one of the first federal standards developed on vehicles and equipment. In developing the standard, NHTSA incorporated requirements from a number of industry consensus standards, in particular SAE standards. Motor vehicle technology was relatively simple compared to today. For example, NHTSA points out that motor-vehicle headlight systems were limited to ones consisting of either two 7" or four 5 ¾" round, sealed-beam units.
Developments during the ensuing years included a number of rectangular, sealed-beam units, replaceable bulb headlamps, and integral beam headlamps, and FMVSS 108 was amended to permit the use of this new technology. Later, the standard was further amended to add requirements for high-mounted stop lamps, side-marker lamps, and side-reflex reflectors to allow for daytime running lamps and to address the conspicuity needs of large vehicles.
However, those amendments were made on an ad hoc basis, which over time resulted in a patchwork organization for FMVSS 108. In addition, when regulated parties had questions regarding how FMVSS 108 should be interpreted — in many instances due to rapid advances in lighting technology not fully anticipated or addressed by the existing regulatory text — they submitted requests for interpretation to the agency on specific issues. Many interpretation letters have been issued dealing with the standard, resulting in a situation where requirements are located directly in its regulatory text and in referenced and sub-referenced SAE standards, and elaborated upon in various agency interpretations.
The result, Van Riper says, was “a very unstructured document” that required a person to either “have a lot of time or a significant amount of expertise to be really able to find all of the individual requirements for the functions that are regulated.”
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