Interpretation ID: nht91-7.51

DATE: December 20, 1991

FROM: Robert W. Smith -- President, Auto Safety Corporation

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1/23/92 (est) from Paul Jackson Rice to Robert W. Smith (A39; Std. 108)

TEXT:

Thank you for your letter of November 15, 1991 in which you confirmed the points of our earlier meeting with Mr. Vinson. Also, I would like to provide an answer to the question you raised as to "...the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp(s) with requirements of Standard No. 108."

We recognize the prohibition specified in the Safety Act against tampering with the motor vehicle license plate lamps, and would call your attention to the fact that those license plate lamps are for the sole purpose of illuminating the license plate itself and are part of the motor vehicle electrical circuit that also includes the front headlights and rear red driving lights. Our device, the license plate frame with built-in supplementary flashing/steady burning stop lamp, is indeed an aftermarket device and is not connected to the aforementioned motor vehicle headlight/rear light electrical circuit and therefore, does not have any effect on that system. Furthermore, our engineering precludes any physical interference and obstruction of visibility of the vehicle's license plate.

In addition, our company recognized the above safety concerns and based its engineering of the license plate stop lamp device on our patented electronic circuitry. It received a patent, in large part, because of its fail-safe features which permit increased safety while operating the motor vehicle.

I hope this explanation clears up your uncertainty about the operation of our device and I would appreciate a response from your office to that effect.