Interpretation ID: 86-5.16

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: David M. Wise -- Gary Precision Products

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. David M. Wise Gary Precision Products 530 Old Post Road #3 Greenwich, CT 06830

This is in reply to your letter of August 7, 1986( asking if Federal Motor Vehicle Safety Standard No. 108, or any other Federal regulation applies to a plastic ice scraper with a reflector on it that you may manufacture.

Although the title of Standard No. 108 is "Lamps, Reflective Devices, and Associated Equipment," the reflective devices covered by the standard are those that are mounted on the rear and side of a motor vehicle, which are necessary for signaling and the safe operation of vehicles during darkness and other times of reduced visibility. It does not apply to ice scrapers. Nor does the other Federal motor vehicle safety standard dealing with reflectivity, Standard No. 125 "Warning Devices," or any other regulation of this Department.

I hope this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

August 7, 1986

Ms. Erika Z. Jones Chief Council National Highway Traffic Safety Administration Room 5219 400 7th St. S.W. Washington, DC 20590

Dear Ms. Jones:

Gary Precision Products manufactures a line of injection molded plastic ice scrapers and snow brushes . We are considering the manufacture of an ice scraper with a reflector on it. The reflector will be on the blade portion of the ice scraper.

We would like to know if there are any laws, rules or regulations governing the manufacture or sale of such a product. I specifically refer to U.S. Dept of Transportation Motor Vehicle Safety Standard # 108.

In my conversation with Mr. Taylor Vincent, the law only refers to motor vehicles themselves, not to portable automotive devices used on them.

We would like something in writing stating that there are no regulations or laws we need to comply with in manufacturing this product.

We thank you for your assistance in this matter.

Very truly yours,

GARY PRECISION PRODUCTS

David Wise