Interpretation ID: 8069
President
One More Run, Inc.
3657 Wildwood Road
Maryville, TN 37804
Dear Mr. Keisler:
This responds to your letter of November 24, 1992, with respect to the manufacture of a replacement taillamp lens for the 1966-67 Dodge Charger. You ask for "all safety standards information pertinent to the manufacture of this replacement lens", and inform us that you "will use only "current DOT and SAE safety approved material to build this item."
As Taylor Vinson explained to you, Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment was amended effective January 1, 1972, to apply to replacement lighting equipment for motor vehicles manufactured on and after that date (the standard had previously applied only to original equipment on passenger cars manufactured on and after January 1, 1969). This means that replacement taillamps designed specificially for the 1966-67 Dodge Charger have never been covered by a Federal motor vehicle safety standard.
Paragraph S5.1.2 of Standard No. 108 does require that plastic materials used for optical parts such as lenses conform to SAE Recommended Practice J576c, May 1970, with certain exceptions. Although this could be construed as requiring compliance of plastics used in any replacement taillamp lens, we do not interpret this as mandating compliance of plastic materials for a lens in a replacement lamp that is itself not subject to Standard No. 108. However, S5.1.2 is the Federal requirement that you would be obliged to meet were you manufacturing new or replacement taillamp lenses for contemporary motor vehicles. I enclose a copy of S5.1.2 and J576c for your information.
We appreciate your desire to meet current safety requirements. Sincerely,
Paul Jackson Rice Chief Counsel Enclosures ref:108 d.12/16/92