Interpretation ID: nht92-9.41

DATE: January 23, 1992 EST

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Robert W. Smith -- President, Auto Safety Corporation

TITLE: None

ATTACHMT: Attached to letter dated 12/20/91 from Robert W. Smith to Paul Jackson Rice

TEXT:

This responds to your letter of December 20, 1991.

In replying to your previous letter on November 19, I observed that "we are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. 108." You have replied that "our engineering precludes any physical interference and obstruction of visibility of the vehicle's license plate," hoping that "this explanation clears up your uncertainty about the operation of our device." You have asked for "a response from your office to that effect."

We appreciate your assurance that your device does not result in any physical interference and obstruction of visibility. However, the device must not affect conformance with the incident light requirements as well. When installed on a vehicle, a license plate lamp must conform with SAE Standard J587 OCT81 License Plate Lamps (Rear Reqistration Plate Lamps). Conformance with the incident light requirements is determined with the lamp in the license plate holder. If the lamp in its holder conforms to J587 with your device installed, then you may be satisfied that we have no further concern.

I enclose a copy of SAE J587 for your reference.

Attachment

Copy of SAE J587. (Text omitted)