Interpretation ID: aiam3724
President
Safety Alert Co.
Inc.
1667 9th Street
Santa Monica
CA 90404;
Dear Mr. Howard: This is in reply to your letter of June 28, 1983, occasioned by wha you believe is our misconception of the way your 'Safety Alert' system operates. In my letter of June 17 I stated that 'Safety Alert', which was intended to flash a yellow bulb installed in the backup lamp system, would create a noncompliance with Standard No. 108 which requires backup lamps to be white in color and steady burning when in use. You now bring it to our attention that your system does not alter the normal operation of the backup lamps which are steady burning when a vehicle is in reverse, even when 'Safety Alert' is installed.; We understood this when we advised you that you could use 'Safet Alert' through any rear lighting system which Standard No. 108 allows to flash for signalling purposes such as the hazard warning or turn signal systems. The converse of this is that 'Safety Alert' cannot be used through any rear lighting system that Standard No. 108 requires to be steady-burning when in use, such as the backup lamp system, even though when used as a backup lamp it is steady burning. I am sorry this was not clear to you.; We are unaware that any foreign manufacturer is failing to comply wit Standard No. 108 by installing a backup lamp system that 'reflects amber' as you have told us.; Sincerely, Frank Berndt, Chief Counsel