Interpretation ID: 15740.ztv

The Honorable Phil Gramm
United States Senator
2323 Bryan Street, #1500
Dallas, TX 75201
Attention: Linda Bazaco

Dear Senator Gramm:

This is in reply to your inquiry of August 3, 1997, on behalf of your constituent, Reggie Lawrence of Midland.

Mr. Lawrence believes that I "hastily misinterpreted" Federal Motor Vehicle Safety Standard No. 108 in informing him by letter of May 30, 1997, that his invention would create a noncompliance with the standard.

Specifically, S5.5.4 of Standard No. 108 requires that vehicle stop lamps be activated upon application of the service brakes. Mr. Lawrence's invention would result in a vehicle's stop lamps remaining activated for six seconds after the brake pedal was released. Because "there is no indication that these lamps must be deactivated when the service brakes are released,"

Mr. Lawrence believes that he is "well within the guidelines of the Safety Standard #108."

It is quite clear to us that implicit in the requirement that stop lamps be activated upon application of the service brakes is that they be deactivated when the service brakes are not applied. Adopting Mr. Lawrence's interpretation would mean that stop lamps could remain lit indefinitely after first being activated by the application of the service brakes. This would result in a following driver having no indication at all that the vehicle ahead was braking, and detract from safety rather than adding to it.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.9/22/97