Interpretation ID: nht92-8.43

DATE: February 27, 1992

FROM: Kevin J. Stoll -- Technical Advisor, Russell Products Incorporated

TO: Taylor Vinson -- Legal Counsel FMVSS - 108, NHTSA

COPYEE: Thomas L. Russell

TITLE: None

ATTACHMT: Attached to letter dated 4/27/92 from Paul J. Rice to Kevin J. Stoll (A39; Std. 108)

TEXT:

My purpose for writing you today is that the "Office of Rulemaking" stated to me that I should address my questions directly to you via letter.

Russell Products is a multi-line distributor to the recreational vehicle and van conversion industry. We are currently selling third brake lights to the van and R.V. industry. We also are familiar with the standards that are in effect for all vehicles that are manufactured in our industry.

However, the purpose for this letter is that I am currently designing a third brake light for the truck cap and truck camper vehicles. Listed below are a few questions that I have not been able to find rulings on. I would appreciate any help or insight that you may have in obtaining the answers to these questions.

1. Are the LED (light emitting diode) being used for third brake light legal?

If so, what are the specifications so that they can be used as a third brake light?

2. a. Where are the truck manufacturers ie. GM, Ford, Dodge locating the third brake fight on pickup trucks?

b. What effect will this have on truck cap manufacturers and the dealer responsibility to the consumer?

c. Can the dealer wire directly to the existing third brake light harness used to light up the factory third brake light?

3. a. We have a customer that would like to mount a flush mounted third brake light in the rear glass window of a truck cap. This window is used also as the rear access door to get to the truck bed from the outside of the truck.

b. This would allow the third brake light to be moveable and not stationary. If a consumer would have an object in the bed of the truck with the window in the open position, allowing for the third brake light to be left in an upward position and no longer viewed from the rear.

Would this application be approved?

4. Could you please enter Russell Products, Inc. on your mailing lists for all future updated mailings on third brake lights passed or discussed at all committee meetings.

If you have any questions or would require additional information, please don't hesitate to call me at 1-800-545-5620. I appreciate your help in advance.