Interpretation ID: 2973yy
Souvenirs of the Future
Suite 201-71
3435 Ocean Park Blvd.
Santa Monica, CA 90405
Dear Mr. Kirchgraber:
This is in reply to your letter of April 16, 1991, with respect to which Federal motor vehicle safety standards, if any, must be met in order to sell an exterior tire/wheel cover with reflective characteristics that will help to make "the vehicle more visible to the surrounding traffic." In addition, you "want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard", and ask for the citation to "appropriate federal test standards from the code of federal regulations for similar automotive accessories."
There are no Federal motor vehicle safety standards that establish performance requirements for reflective material of this nature, or for wheel coverings on exterior-mounted tires. The standard on vehicle lighting, Motor Vehicle Safety Standard No. l08, does prohibit, as original equipment, the installation of a "reflective device or other motor vehicle equipment" that impairs the effectiveness of lighting equipment required by the standard. It is theoretically possible that your material could create glare in the eyes of a following operator so that (s)he would fail to respond to a stop signal, or a turn signal. The samples submitted with your letter are too small for us to judge its reflectivity, and we suggest that you conduct your own tests, approaching a vehicle with the tire cover from the rear, with headlamps on the lower beam. This, to us, is preferable to your redesigning the material to conform to any federal test standard relating to reflectivity.
Although the color of lighting equipment on the rear is generally red, with amber permitted for turn signals, and white required for back up lamps, we do not believe that the use of additional colors would create any confusion. In short, we believe that the wheel cover will be perceived for the wheel cover it is.
I hope that this responds to your concerns.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:l08 d:5/6/9l