Interpretation ID: aiam2808
President
Mohs Seaplane Corporation
2355 University Avenue
Madison
WI 53705;
Dear Mr. Mohs: This is in reply to your letter of May 5, 1978, asking 'what i necessary for the rewriting of [Motor Vehicle Safety Standard No.] 108 to include my . . . system for vehicle identification.' As you have described this reflective device, it is a polyvinyl extrusion in which is placed polyester tape which 'becomes a continuous reflector down the side of a vehicle - amber toward the front, red on the rear half of the vehicle and red across the back.' You state that in your experimental installation you are 'retaining the 3' spot reflectors as required in Standard 108.'; If your material conforms to Federal Specification L-S-300 and, as use on the vehicle, meets the performance standards in Table 1 of SAE Standard J495d, 'Reflex Reflectors,' March 1967, it could be used as the front and rear reflex reflectors required by Standard No. 108. However, if it does not meet this specification, Standard No. 108 would not prohibit the sale and installation of your system as original equipment, or as an aftermarket accessory, provided it is supplementary to the side and rear reflectors required by Standard No. 108. Thus, no Federal 'approval' of your system is required. A change in Standard No. 108 is required only if you believe your system should be mandatory on all motor vehicles. In the event you wish to petition for such an amendment of Standard No. 108, I enclose a copy of our rulemaking procedures.; Yours truly, Joseph J. Levin, Jr., Chief Counsel