Interpretation ID: aiam3512
President
Grancor
Inc.
929 Olympic Boulevard
Santa Monica
CA 90404;
Dear Mr. Granatelli: This is in reply to your letter of November 17, 1981, with respect t 'a non-substantive disagreement' of your Safety Alert Device 'with a strict interpretation of (FMVSS No. 108)'. Your system is wired into and operated through a vehicle's back-up lamp system which you have modified by adding 'a yellow sleeve over half of the back-up light bulb'. You state that the light cast is 'essentially the same as the white light. You further say that any deviation from Standard No. 108's requirement that back-up lamps emit white light is 'nonsubstantive'.; I assume that your letter to me is in response to the one that Georg Parker, Chief, Crash Avoidance Division, sent you on September 2, 1981. In that letter he explained that S4.1.3 prohibits the addition of equipment 'that impairs the effectiveness of lighting equipment' required by Standard No. 108, and stated that any activation of your system while the back-up lamps are in operation would be covered by this prohibition. As for color, you were informed that S4.1.3 imposed an absolute prohibition if the color of the light emitted by the deceleration warning system were green or white.; We cannot concur that the deviation from Standard No. 108 i 'non-substantive'. Standard No. 108 requires back-up lamps to be installed in motor vehicles and to emit a white light. We view S4.1.3 as precluding any device that would operate lighting equipment required by Standard No. 108 for a purpose other than that for which it is originally installed. Further, even if your system did not operate through the back-up lamp system but through separate and additional lamps, we would view use of a color other than red or amber as an impairment of the equipment originally installed to indicate the deceleration through braking of the vehicle (*i.e.*,, stop lamps).; Sincerely, Frank Berndt, Chief Counsel