Interpretation ID: aiam3106
Laboratory Manger
R. E. Dietz Company
225 Wilkinson Street
Box 4833
Syracuse
NY 13221;
Dear Mr. Bachynsky: This is in reply to your letter of August 21, 1979, asking for a interpretation of Federal Motor Vehicle Safety Standard No. 108 as it may apply to a proposed new product of your company.; This product, as you have described it, is a bi- directional Emergenc Vehicle Warning Lamp, with one lens facing to the front of the vehicle, and one to the rear. Each lens contains a 5/8 inch wide bank of relfex (sic) reflector around its periphery. The lamp would be supplied in a variety of colors (red, blue yellow) and a similar device. Less the reflex reflector area, is currently in production.; You have asked whether the inclusion of the reflex reflector in th device, 'impairs the effectiveness of the required equipment' within the prohibition of S4.1.3. You have also asked whether the equipment and location tables of Standard No. 108 restrict the use of a red reflex reflector facing the front and yellow reflex reflector facing the rear.; The determination of whether installation of additional lightin devices impairs the effectiveness of required equipment may be made either by the vehicle manufacturer or by NHTSA. Since your company already markets an emergency vehicle warning lamp we shall assume for purposes of discussion that vehicle manufacturers have determined that the lamp as currently manufactured does not impair other lighting equipment. Nor does it appear to us that the addition of the limited reflex reflector area would contribute to a degradation of the effectivenss (sic) of required lighting equipment, although a definitive judgment could not be made until the lamps were actually installed on a vehicle. The tables do not apply to supplementary lighting equipment such as your emergency lamp though the agency believes there is less likelihood of confusion if the public associates amber lighting devices with the front part of a vehicle, and red ones with the rear.; Sincerely, Frank Berndt, Chief Counsel