Interpretation ID: aiam3995
Director of Marketing
Automotive Division
Amco Manufacturing Corporation
7425 Fulton Avenue
North Hollywood
CA 91605;
Dear Mr. Kagan: This is in reply to your letter of July 19, 1985, asking if deck-mounted rack loaded with luggage would cause a violation of the center high-mounted stop lamp provisions of Motor Vehicle Safety Standard No. 108.; The answer is no. Compliance with Standard No. 108 is determine independent of whether the luggage rack is loaded. However, if the rack is installed before sale of the vehicle to its first purchaser, or if it is installed after sale by a person other than the vehicle owner, care must be taken to insure that the photometric and visibility requirements for center high-mounted stop lamps continue to be met with the unloaded rack in place.; The lamp is intended to reduce the incidence of rear end collisions Loading the rack in a manner that obscures the light will reduce the safety benefits that the lamp provides both the driver of the car, and of any vehicle that follows, and is a practice that should be discouraged.; If you have any further questions, we shall be happy to answer them. Sincerely, Jeffrey R. Miller, Chief Counsel