Interpretation ID: aiam0573
Chief Engineer
K-D Lamp Company
1910 Elm Street
Cincinnati
OH 45210;
Dear Mr. Ward: In your letter of January 20 to Mr. Vinson of this office you ask fo an interpretation of paragraph S4.7 'Replacement Equipment' of Motor Vehicle Safety Standard No. 108.; Standard No. 108 applies to motor vehicles manufactured on or afte January 1, 1972. The standard specifies items with which these vehicles must be equipped. The standard also applies to items manufactured on or after January 1, 1972, intended to replace items required by Standard No. 108 to be original equipment on these vehicles. This replacement equipment must be manufactured to conform to Standard No. 108 and certified as meeting all applicable Federal Motor vehicle safety standards.; The standard does not require conformance or certification of item intended as replacement equipment on vehicles manufactured before January 1, 1972 (sic) In this circumstance a manufacturer may continue to manufacture replacement equipment that does not meet Standard No. 108.; Sincerely, Richard B. Dyson, Assistant Chief Counsel