Interpretation ID: aiam0460
Engineering Representative
Liaison Office in U.S.A.
Nissan Motor Co.
Ltd.
400 County Avenue
Secaucus
NJ
07094;
Dear Mr. Nishibori: In your letter of October 14 you ask whether reflex reflectors on th tail gate of a pick-up truck, as shown in Figure 1 of the drawings you enclosed, meet the requirements of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Standard No. 108 requires, in part, that reflex reflectors be mounte 'on the rear' of a vehicle. Compliance with the requirements of Standard No. 108 is judged with the vehicle in its normal road operating condition. In our view, a pick-up truck is normally operated with the tail gate in a closed position, and the reflex reflectors mounted as shown in Figure 1 appear to meet the rear reflector location requirements of Standard No. 108.; Sincerely, Lawrence R. Schneider, Chief Counsel