Denial of Petition for Rulemaking; Federal Motor Vehicle Safety Standards

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This document denies a petition from Koito Manufacturing Co., Ltd. for rulemaking to permit an alternative performance requirement (allowing permissible moisture presence) for certain types of headlamps after completion of the humidity test. The humidity test of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, was shortened in duration in 1991 to accommodate another petition from Koito; thus, this petition is somewhat repetitive. The requirement of no visible moisture inside the headlamp has existed for replaceable bulb headlamps since their inception in 1983. The claim by Koito that the requirement is not a performance standard but a design standard is without merit. Koito's proposed supplementary corrosion test for headlamps with visible moisture present after a humidity test does not seem to support its claim of no long-term photometric degradation in these headlamps passing the test.