Interpretation ID: aiam3937
19459 Manor
Detroit
MI 48221;
Dear Mr. Hart: This is in reply to your letter of February 11, 1985, to former Chie Counsel Frank Berndt asking for an interpretation that a combination stop lamp-rear view mirror you have invented would be permissible under paragraph S4.4.1 of Standard No. 108.; That paragraphs precludes combining a center high-mounted stop lam with any other lamp or reflective device. You have concluded that the prohibition applies only to passenger cars manufactured after September 1, 1985, 'and does not prohibit application of my device to vehicles manufactured prior to the effective date of the mandate.'; Actually, S4.4.1 does not apply to your device at all. The lam established by the standard is one that is mounted on the vertical centerline of the vehicle, at or near the rear window with no relationship to the forward left side of the vehicle where your combination lamp-mirror would be located. Standard No. 108 does contain in paragraph S4.1.3 a prohibition against additional lighting devices that impair the effectiveness of the lighting equipment required by the standard. But on the basis of the facts as you have presented them to us, we cannot say that impairment would exist. We therefore conclude that your device is not prohibited by Standard No. 108 as either original or replacement equipment on any motor vehicle.; However, Motor Vehicle Safety Standard No. 111, *Rearview Mirrors* does relate to your device. Passenger cars are required to be equipped with an outside rear view mirror on the driver's side, under paragraph S5.2.2 '...neither the mirror nor the mounting shall protrude farther than the widest part of the vehicle body except to the extent necessary to produce a field of view meeting or exceeding the requirements of S5.2.1.' Some of your designs show the lamp portion at the left end of the device's housing resulting in a wider unit than one incorporating a mirror alone. We recommend that you re-examine these designs with paragraph S5.2.2 in mind, relocating the lamp to the area either above or below that of the mirror surface if you conclude that the combination mounting would not comply with Standard No. 111.; There is no similar mounting requirement for driver's side mirrors o vehicles other than passenger cars, and your designs for mirrors on these vehicles would appear permissible under Standard No. 111.; Sincerely, Jeffrey R. Miller, Chief Counsel