Interpretation ID: nht95-1.82

TYPE: INTERPRETATION-NHTSA

DATE: March 1, 1995 EST

FROM: Marshall S. Reagle -- Sate-Lite Mfg. Co.

TO: Pat Boyd -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/17/95 LETTER FROM PHILIP RECHT TO MARSHALL S. REAGLE (A43; STD. 108)

TEXT: Dear Pat:

As I stated in my telephone conversation on Monday, February 27, 1995, I would send you a confirming letter of my interpretation of FMVSS 108 and our discussion regarding retro-reflectors.

You stated that any retro-reflector would have to be made in intervals of 4 inches. The center or 0 degree would be at the two inch mark and the reflective reading would have to comply with S5.7.2.1 (b) and (c) of FMVSS 108.

Also, that regardless of size, 4, 8, or 12 inches in length, your testing requirements and standards are strictly for a 4 inches segment, (ie. you would mask off any area of a retro-reflector other than 4 inches and test the segment alone.) The width of the retro-reflector has not been established as with sheeting, therefore, as long as the photometric requirements are achieved, the width is a variable.

Below is a sketch of how NHTSA is asking the retro-reflector to function:

TOP VIEW

45 degrees L 30 degrees L 0 degrees 30 degrees R 45 degrees R

45L-30L, 30R-45R 30L-0-30RRED 75 MILLICANDELAS/LUX RED 300 MILLECANDILAS/LUX CLR 300 " " CLR 1250 " "

Please review this letter and sketch with legal counsel as soon as possible, we would like to begin work on this project immediately.

Thank you for your time and efforts in this. I appreciate all of your input.