Interpretation ID: 2249y
2605-C Norris Court
Philadephia, PA 19121
Dear Mr. Holmes:
This is in reply to your recent undated letter, responding to our letter of October 31, l989, with respect to your Strobalarm lighting device.
In that letter, we advised you that the clearance avoidance portion of the Strobalarm appeared intended to serve as a center highmounted stop lamp, and that under Standard No. l08, that lamp could not be combined with any other lamp or reflective device. Your recent letter and diagrams enclosed with it indicate that the strobe alarm and its LCD display "is wired and housed separately and functions independently from the collision avoidance light." However, your diagrams do not indicate the orientation of the device when installed. Further, your description is unclear. You state that the base will fit in front of the collision avoidance lamp, but you don't state whether the "front" of the lamp is the side nearest the front of the vehicle, or the side emitting light to the rear of the vehicle).
Nevertheless, your remarks do clearly respond to our earlier concern about combinations. Further, you have stated that the alarm and LED portion of the lamp will operate only when the vehicle is at rest, and not at times that the collision avoidance lamp is in operation. It therefore appears that installation and use of this device, as you have described it, would not violate any Federal regulation.
We note the comment in your enclosure that the device "has been designed to meet the department of transportation (lighting division) standards and regulations". This is somewhat inaccurate as there are no Federal specifications for the device to meet, only prohibitions to avoid. Thus, we believe it would be more accurate to say that the device "has been designed not to conflict with standards and regulations of the U.S. Department of Transportation."
Sincerely,
Stephen P. Wood Acting Chief Counsel / ref:l08 d:l/22/90