Interpretation ID: 1985-04.31

TYPE: INTERPRETATION-NHTSA

DATE: 11/18/85

FROM: JACK H. MCDANIEL -- TRIM PLUS AUTOMOTIVE ACCESSORIES

TO: JEFFEREY R. MILLER -- CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 02/20/89 FROM ERIKA Z. JONES -- NHTSA TO JACK H. MCDANIEL LETTER DATED 01/09/86 FROM JACK MCDANIEL TO JEFFREY R. MILLER -- NHTSA

TEXT: Dear Mr. Miller:

Ours is a company specializing in the installation of automotive trim accessories. Most of our services are to the franchised dealers of the major automobile makers, installing accessories on their pre-delivered cars.

Recently there has been some confusion among myself and colleagues regarding the new safety standards for 1986 vehicles concerning the center high-mounted stop lamps which, I have been told, is Motor Vehicle Safety Standard No. 108. Since some of my orders are for installing deck-mounted luggage racks with cross bars on 1986 vehicles, I wonder if you could give me some information about how the new safety standards might affect this. I will list the things I am particularly concerned about.

1. Will deck-mounted racks that have cross bars violate the new safety standards? It seems to me that many racks can be mounted and positioned so that the high-mounted stop lamp is still clearly visible from the rear. How can we determine if one would cause a violation?

2. Would a deck-mounted rack loaded with luggage cause a violation?

I shall await your answers with great interest, Mr. Miller. Many thanks for any information you can give me. May I please here from you as soon as possible?

Respectfully,