Interpretation ID: nht92-9.57

DATE: January 7, 1992

FROM: Thomas J. Magnan -- Sergeant, Traffic Safety Division, Metropolitan Police Department, City of St. Louis, Mo.

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: Re: "Hella" brand Position Indicator Lamp

ATTACHMT: Attached to letter dated 2/11/92 from Paul Jackson Rice to Thomas Magnan (A39; Std. 108)

TEXT:

I saw a demonstration of the new "Hella" brand Position Indicator Lamp at a safety show I attended in British Columbia, in September 1991.

I have since contacted a Hella distributor in St. Louis, Mo with questions on where this may be purchased and the price of the item. He informs me that Hella of Germany has told him that to sell or install this item on a vehicle in the United States is against the law, as it has not as yet been approved for sale or use in this country. I then contacted a Mr. Scott Toivanen at 1-604-687-7779 with the Canadian Distributor OBIRON ENTERPRISES INC. Mr. Toivanen informed me that he has attended meeting with representatives from this country, specifically NHTSA and DOT-OMC, and both agencies approved of this device, so long as the maximum vehicle width was not exceeded. I contacted Mr. Kevin Cavey at NHTSA, who was reportedly at one of these meetings and Mr. Cavey told me he didn't know what I was talking about, and suggested I write to you.

Please advise as to whether this item may be used on vehicles in the United States, providing the maximum vehicle width of 102.36 inches is not exceeded.

Enclosed please find related information on the product.

Attachments (Text and graphics omitted):

Brochure entitled IPS Corporation Introduces the Position Indicator Lamp. Indicates that the lamp is distributed in Alberta and British Columbia by Obiron Enterprises Inc.

Copy of a letter from Claus Bergmeier, President of International Product Specialities (IPS), announcing a new safety marker lamp for commercial vehicle application.

Copy of a report, dated 2/5/91, from the Canadian Standards Association, containing the results of examinations and tests of the IPS position indicator lamp. Demonstrates compliance with applicable SAE standards.