Interpretation ID: nht90-3.87

TYPE: Interpretation-NHTSA

DATE: September 10, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Thomas J. Loughran -- V.P. Engineering, The Grote Manufacturing Company

TITLE: None

ATTACHMT: Attached to letter dated 8-13-90 from T.J. Loughran to J.R. Curry; Also attached to article entitled It's the Law - Rear Amber Reflector (Text omitted)

TEXT:

Thank you for your letter to the Administrator of August 13, 1990, in which you point out an error in an interpretation of Standard No. 108 furnished The Bargman Company on February 26, 1990.

The interpretation intended to refer to an amber turn signal lens, not an amber taillamp lens, as you surmise. We regret the confusion that we have inadvertently caused; the agency does not intend to allow an amber taillamp lens.

Nevertheless, tbe interpretation correctly stated that use of an amber reflex reflector with an amber lamp on the rear is permissible, providing that it does not impair the effectiveness of the required rear lighting and marking equipment, but that it is nevertheless subject to State and local laws regarding vehicles in use. This is consistent with long-standing interpretations on the use of lamps, reflective devices, and associated equipment other than those that Standard No. 108 requires.