Interpretation ID: aiam3238
Vice President
Whitley & Whitley
Inc.
20600 Chagrin Boulevard
Tower East
Shaker Heights
Ohio 44122;
Dear Mr. Whitley: This responds to your February 8, 1980, letter asking whether th CarVan that you manufacture would be required to comply with Federal safety standards. The CarVan is designed to be mounted over the trunk of a car and weight approximately 80 pounds.; The CarVan is considered a piece of motor vehicle equipment fo purposes of compliance with the motor vehicle safety standards. Since it does not slide into the cargo area of a truck, however, it would not be considered a slide-in camper subject to Standard No. 126, Truck-Camper Loading. However, as a piece of equipment, it would be required to comply with Standard No. 205, *Glazing Materials*. I am enclosing an information sheet detailing where you can obtain a complete copy of all motor vehicle safety standards.; The agency notes that the CarVan would be installed in such a locatio that it would obscure the rear lights of the vehicle upon which it is mounted. The agency considers this to be very dangerous and concludes that you should adopt a tail light system for the CarVan. The Federal safety standard for lighting is Standard No. 108. Without a tail light system, the agency concludes that the installation and use of your CarVan would constitute a safety related defect, and we would exercise our authority to require any such defect to be remedied. We also note also that many States prohibit any device that covers the licence plates.; The agency would like to take this opportunity to correct som misinformation that was supplied to you an May 4, 1978, when we responded to your previous request for information on a camper that was designed to be loaded in a car's trunk.; In that letter, the agency stated that the camper would be required t comply with Standard No. 126. That statement is incorrect. Since your camper is designed for a passenger car and not a truck, it would not be required to comply with Standard No. 126. It would be subject to the other standard mentioned above for the CarVan. We regret any inconvenience our error may have caused you.; Sincerely, Frank Berndt, Chief Counsel