Interpretation ID: aiam3320
Inc. 27621 Parkview Boulevard Warren
Michigan 48092;
Dear Mr. Haenchen: This is in reply to your letter of April 2, 1980 asking for information of your interpretation of Section 4.31 of Motor Vehicle Safety Standard No. 108. This section states that lamps 'shall be securely mounted on a rigid part of the vehicle...that is not designed to be removed except for repair.' It is your belief that this section would allow a configuration in which back-up lamps and license lamps could be mounted on the deck lid. We concur with this interpretation. The requirement for rigidity is meant to ensure that lamps and reflectors do not sway in the wind on hinges or flexible mud flaps when the vehicle is in motion. The passenger cars you propose to manufacture will normally be operated with the deck lid closed and the lamps in full view on a rigid part of the vehicle as the standard requires. However, placement of a stop lamp and taillamp on a deck lid could be viewed as a defect in performance, and hence a safety related defect requiring notification and remedy. Sincerely Frank Berndt Chief Counsel;