Interpretation ID: aiam1233
President
Sate-lite Mfg. Company
6545 W. Irving Park Road
Chicago
Illinois 60634;
Dear Mr. May: This is in response to your petition of July 26, 1973, to modify th water immersion requirements of Standard 125, *Warning devices*, and the grounds that the test is more severe than typical weather conditions. The standard requires immersion of the device for 2 hours in water at a temperature of 100 degrees F. without warpage or separation of the reflective material from the support material.; Your reference to the device as a flare and to its immersion in 5 fee of water for an indefinite period makes it unclear whether you are referring to the standard as it will be effective on January 1, 1974. The final rule balanced the likelihood of water damage against numerous other considerations including cost and reuse. The 2-hour immersion requirement detailed above is intended to ensure that the device is undamaged and reuseable after an exposure to rain during any emergency deployment. In contrast, the 12-hour spray test of Standard No. 108 which you suggest as an alternative is used for reflex reflectors which are permanently mounted on a vehicle and are subject to regular and long exposure to blowing water. That spray test does not adequately simulate the relatively short but severe exposure to which a warning device would be subject in a steady rain. It is in such adverse weather conditions, of course, that the use if the device will be most important.; For these reasons, your petition is denies on the grounds tha preservation and reuse of the device justify the immersion requirement. Thank you for your interest in developing a functional warning device standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;