Interpretation ID: 86-4.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/18/86

FROM: Z. TAYLOR VINSON -- SENIOR STAFF ATTORNEY NHTSA

TO: INTERPS. - STD. NO. 108 REDBOOK (3)

TITLE: CHMSL INTERPRETATION

TEXT: On July 16, 1986, a mechanic phoned with the following question: if a customer wishes to have a deck lid luggage rack installed, and that rack incorporates a center high-mounted stop lamp that is mounted between the rack and the deck lid, and the original interior mounted center stop lamp remains in place, would Standard No. 108 prohibit such an arrangement?

I replied that it wouldn't, assuming that the rack itself in an unloaded condition prevented the lamp from full compliance with photometric and/or visibility requirements; paragraph S4.3.1.1. requires a supplementary or auxiliary lamp meeting Standard No. 108's requirements whenever motor vehicle equipment prevents compliance by a required item of lighting equipment.