Interpretation ID: aiam5027
IL 60131;
"Dear Mr. Rovtar: This responds to your letter of May 28, 1992, askin for 'a written ruling' that the product you described 'meets current SAE/DOT guidelines.' The product is intended for the vehicle towing trailer market. Currently, lamps on towed vehicles are activated by splicing into the wiring harness of the towing vehicle. Your product eliminates the need for this type of hard wiring. This product 'utilizes photodetectors to read the output of the towing vehicle's stop and turn signal lamps, and in turn activate the lamps of the towed vehicle.' Photodetectors are embedded in suction cups which are attached to the towing vehicle's stop and turn signal lamps. The device is plugged into the cigarette lighter receptacle of the towing vehicle, and the harness of the towed vehicle is plugged into the device. When the stop lamp or turn signals of the towing vehicle are activated, the photodetectors read the light emitted, and the towed vehicle's lamps are activated via the completed circuit. For purposes of this discussion we shall assume that the device is intended for aftermarket distribution. Further, from your description, it appears to be the type of device that is simple enough to be installed by the vehicle owner. The product itself is not directly regulated by Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment, because it is not replacement equipment intended to replace original equipment. Its installation on a vehicle in use by the vehicle's owner is outside the prohibition contained in the National Traffic and Motor Vehicle Safety Act. That prohibition forbids 'manufacturers, distributors, dealers, and motor vehicle repair businesses' from 'rendering inoperative, in whole or in part,' mandated safety equipment such as stop lamps and turn signal lamps. Were the device installed by a person in these categories we would be concerned that the addition of the suction cups would partially obscure the original equipment stop and turn signal lamps and, thus, render them 'partially inoperative' within the meaning of the prohibition. That concern is not lessened by the fact that the device may be installed by a person not covered by the prohibition, such as the owner of the towing vehicle. However, as a practical matter, we realize that the safety impact may be minimal since the presence of the trailer will obscure the lamps on the towing vehicle to which the suction cups are applied. We cannot advise you on whether the product meets SAE requirements. The legality of the use of equipment that is not regulated by NHTSA is determinable under the laws of States where the towing-towed vehicle combinations are operated. We are unable to advise you on these laws, and suggest that you write the American Association of Motor Vehicle Administrators, 4600 Washington Boulevard, Arlington, Va. 22203, for an opinion. Sincerely, Paul Jackson Rice Chief Counsel";