Interpretation ID: aiam3985
8 P Origionals
2892 Crownview Dr.
Rancho Palos Verdes
CA 90274;
Dear Mr. Pesce: Thank you for your May 18, 1985 letter inquiring about the existence o any Federal safety requirements applicable to your projected sale of colored windshield wiper blades.; Under the National Traffic and Motor Vehicle Safety Act, this agenc has issued Federal Motor Vehicle Safety Standard No. 104, *Windshield Wiping and Washing System*, applicable to new motor vehicles. While this standard does not regulate wiper color, it does among other things, require that a wiping system clear a minimum percentage of a vehicle's windshield; In addition, Standard No 107, *Reflecting Surfaces*, also applies t new motor vehicles. This standard specifies reflecting surface requirements for certain components, including windshield wiper blades, in the driver's field of view. Its purpose is to reduce the likelihood the unacceptable glare from reflecting surfaces will hinder safe and normal operation of the vehicle.; If a new vehicle equipped with your blade did not comply with Standar No. 104 or Standard No. 107 due to some aspect of that blade, the sale of that car to the public would be a violation of the prohibition in section 108(a)(1)(A) of the Act against the sale of noncomplying vehicles.; As to used vehicles, you should be aware that section 108(a)(2)(A) o the Act prohibits manufacturers, distributors, dealers and vehicle repair businesses form knowingly rendering inoperative equipment or elements of design installed on a vehicle under Federal motor vehicle safety standards. Care should be taken that the installation of your product would not have that effect. A rendering inoperative might occur if, for example, your blade were not large enough to enable the wiping system to clear a sufficient area of the windshield. We urge you therefore to ensure that the substitution of your blade for an original equipment blade provided by a vehicle manufacturer would enable the wiping system to continue to perform as required by Standard No. 104, and would not produce unacceptable glare in the driver's field of view, as required by Standard No. 107.; I hope this information is helpful. Sincerely, Jeffrey R. Miller, Chief Counsel