Interpretation ID: aiam0752
1701 E. Frierson Avenue
Tampa
Florida 33610;
Dear Mr. Navarro: I am writing in response to your letter of June 13, 1972, regardin Standard No. 125, Warning Devices. In addition to the final rule (37 F.R. 5038) a copy of which we have already sent to you, a reconsideration and amendment was published in the *Federal Register* on June 22, 1972 (37 F.R. 12323). I enclose a copy of that notice.; You enclose a sketch of a warning device which you have designed, an you ask whether the manufacture of such a device would be permitted under Standard 125. From your drawing the device appears to consist of an 'orange fluorescent colored' balloon to which a triangle of 'reflex-reflective' tape is affixed. The device is inflated and attached to the vehicle roof by a magnet. The device does not have a self-contained energy source, and therefore must meet the shape, size, and performance requirements of Standard 125.; The balloon device as shown in the sketch fails to meet a number of th Standard 125 requirements, including configuration, luminance, (the triangle itself must meet the luminance requirements,) stability, and durability. (See paragraphs S4.2, S4.5, S4.6 and S4.7 of the standard.) accordingly, manufacture of the device as it appears in the drawing would be prohibited by Standard 125.; I hope this answers your questions. Sincerely, Richard B. Dyson, Assistant Chief Counsel