Interpretation ID: aiam1971
Esq.
Messrs. Bernard & Bernard
4100 One Shell Plaza
Houston
TX 77002;
Dear Mr. Bernard: This is in reply to your letter of May 28, 1975, providing furthe information for our determination whether certain 'safety lights' would violate the National Traffic and Motor Vehicle Safety Act of 1966.; There is no Federal prohibition against sale of this accessory in th aftermarket. It would, however, be subject to regulation by the states. For the following reasons, it could not be used as original equipment. Standard No. 108 requires a minimum spacing of 4 inches (edge to edge) between the stop lamps and the rear turn signal lamps and a minimum spacing of 9 inches (centerline to centerline) between the turn signals. The purpose of this spacing is to provide a distinctive indication of the turning direction. A flashing stop lamp located in close proximity to the steady-burning stop lamp required by Standard No. 108 would, in our opinion, impair the effectiveness of the rear turn signal within the meaning of S4.1.3, during a combined braking and turning operation. Such a lamp would also be prohibited by S4.6(b) which, in effect, requires all original equipment stop lamps to be steady burning.; Yours truly, Richard B. Dyson, Assistant Chief Counsel