Interpretation ID: 2911yy
Vice President Sales
Markets Unlimited Group, Inc.
P.O. Box 289
Conestoga, PA 17516
Dear Mr. Vonderheide:
This responds to your letter of March 6, l99l, asking for the "application(s) necessary for the Department of Transportation approval of a new product." The product is described only as a "Safety Light."
The Department has no authority to approve or disapprove items of motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, the National Highway Traffic Safety Administration establishes the Federal motor vehicle safety standards that apply to motor vehicles and/or motor vehicle equipment, and which must be met by the manufacturers of any vehicles or equipment to which the standards apply.
Unless your product is intended to replace an existing light found on motor vehicles, it would not appear to be directly covered by Standard No. l08, which establishes Federal requirements for motor vehicle lighting. If indeed it is intended as an additional light, under Standard No. 108 supplementary lighting equipment is permissible as original equipment on motor vehicles provided that it does not impair the effectiveness of lighting equipment required by the standard. Supplementary lighting equipment is also permissible under the Act for vehicles in use, provided its installation by a manufacturer, distributor, dealer, or motor vehicle repair business does not render wholly or partially inoperative any element of design or device installed in accordance with any Federal motor vehicle safety standard. Without knowing more of your device, we can provide you only this general guidance.
The use of equipment on bicycles is under the authority of the Consumer Product Safety Commission, 5401 Westbard Avenue, Bethesda, Md. and we are unable to advise you of their requirements.
The use of supplementary lighting equipment is also regulated by the individual States. We are unable to advise you on these laws, and suggest you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:l08 d:3.29/9l