Interpretation ID: aiam3297
Government Relations Manager
Avery International
Specialty Materials Division
50-L Edwards Ferry Road
Leesburg
VA 22075;
Dear Mr. Lundregan: This is in reply to your letter of April 16, 1980, asking whether Moto Vehicle Safety Standard No. 108 allows 'reflective markings (such as red diagonal stripes on a white reflective background) [to] be used to increase visibility on the front of [trucks and heavy vehicles]'.; You are correct that Standard No. 108 does not directly address thi question. The section of the standard that appears most pertinent to it, however, is S4.1.3 prohibiting the installation as original equipment of any reflective device 'that impairs the effectiveness of lighting equipment required by' Standard No. 108. We would be concerned, for example, if reflective materials were installed in a manner that might cause confusion with headlamps or front turn signal lamps. We also wish to point out that under the standard the use of the color red is at the rear of motor vehicles and that its appearance in any other location might also cause confusion.; However, as a practical matter the use of reflective materials as truc and heavy vehicle equipment sold either as original equipment or in the aftermarket is governed by requirements of the Bureau of Motor Carrier Safety (Federal Highway Administration) which prohibit use of the color red on the front of a vehicle. You should review their requirements before proceeding with your marketing plans. (49 CFR 393.26(e)(4)).; Sincerely, Frank Berndt, Chief Counsel