Interpretation ID: 1985-01.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/16/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. William Shaw

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William Shaw Sales Manager Shinn Fu Co. of America, Inc. 1004 Andover Park East Seattle Washington 98188

Dear Mr. Shaw:

This in in reply to your letter of December 5, 1984, with respect to the permissibility under Federal regulations of a "Supplemental Eye-Level Rear Stop Light" which provides functions additional to a stop signal.

Federal Motor Vehicle Safety Standard No. 106 Lamps, Reflective Devices and Associated Equipment specifies requirements only for center high-mounted stop lamps as original equipment on passenger cars, and for equipment that replaces original equipment center high mounted stop lamps.

If you offer this device to new car dealers for installation on new cars before their sale, the dealer bears the responsibility for insuring that the car he sells complies with the center high mounted stop lamp requirements for new motor vehicles. On vehicles manufactured before September 1, 1986, equipped with the center lamp, that lamp may flash with the hazard warning lamp, but it cannot be combined with other lighting functions such as turn signals.

However, the device you wish to offer appears intended as an aftermarket device and not intended as original equipment for passenger cars. If this assumption is correct, there is no Federal standard that applies to it, and its legality must be determined according to the law of each State where it will be in use.

We hope that this information has been helpful. Sincerely, Frank Berndt Chief Counsel U. S. Dept of Transportation Dec. 5, 1984 Office of Chief Counsel NHTSA 400 7th St. S.W. Washington, D.C. 20590 Dear Sir,

We're a manufacturer of Supplemental Eye-Level Rear Stop Light and we understand it must meet the requirement of Federal Standard if we want to marketing this product.

Now, our question is: If we design it with multi functions, will it be O.K br D.O.T? That means it is designed with not only the stop light function, but also is designed with the hazard flashing light function for emergency use and with the automatic warning flashing light function if this supplemental light catches the high-beam bright lighting from the rear vehicle which approaches closely behind you in a short, unsafe distance. The designed is patented and is definitely helpful for highway safety.

Please help us by confirming this letter as soon as possible or advising us otherwise. Thank you in advance for your great help. Shinn Fu Co. of America Inc. William Shaw Sales Manager WS/ny Encl.