Interpretation ID: aiam2206
Esq.
1700 Pennsylvania Avenue
N.W.
Washington
DC
20006;
Dear Mr. Heffron: This is in reply to your letter of February 13, 1976, asking for confirmation of your understanding that Motor Vehicle Safety Standard No. 108 does not apply to lighting equipment intended as replacement equipment on motor vehicles manufactured before January 1, 1972.; You are correct in your interpretation. The effective date of Standar No. 108 in its current form is January 1, 1972. Therefore, the term 'any vehicle to which this standard applies' contained in S4.7.1 means a motor vehicle manufactured on or after January 1, 1972, and school bus signal lamps intended as replacements for similar lamps on pre-1972 buses are not required to conform to Standard No. 108. This also means, of course, that the manufacturer has no obligation to certify conformance to all applicable Federal motor vehicle safety standards. As motor vehicle equipment, however, its manufacturer would be subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act in the event of the determination of a safety related defect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel