Interpretation ID: 0797
Regional Sales Manager
ResTech
6120 East 58th Avenue
Commerce City, CO 80022
Dear Mr. Lieb:
This is in reply to your letter of February 27, 1995. You report that "a manufacturer of sealed beam automotive head lamps . . . was told by [an adhesive supplier]. . . that D.O.T. 'approval' is required prior to changing the adhesive used on head lamps."
Subsequently, you were told by Blane Laubis of this agency "that D.O.T. does not test, approve, or specify any adhesives, but just verifies that the completed unit meets the prescribed standards, and passes the appropriate tests." You ask if this is correct.
Mr. Laubis is correct. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment establishes requirements that must be met by sealed beam headlamps. As you learned in your review, Standard No. 108 contains no specifications for adhesives. This means the manufacturer may choose the adhesive that appears best suited to ensuring that its particular sealed beam headlamp complies with the performance requirements of Standard No. 108. The approval of the agency is not required. The agency frequently buys and tests all types of headlamps as part of its compliance enforcement program.
I hope that this letter is sufficient for your purposes.
Sincerely,
Philip R. Recht Chief Counsel ref:108 d:4/10/95