Interpretation ID: 86-1.47

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Kevin Rossman

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Kevin Rossman Vice president - Sales & Marketing The Highland Group 9300 Midwest Avenue Garfield Heights, Ohio 44125

Dear Mr. Rossman:

This is in reply to your letter of January 13, 1986, to the former chief counsel of this agency, Jeffrey R. Miller, in which you ask whether a deck-mounted luggage rack loaded with luggage is a noncompliance with Federal Motor Vehicle Safety Standard No. 108.

The answer is no. Compliance with Standard No. 108 is determined independent of whether the luggage rack is loaded. However, if the rack is installed before sale of the vehicle to its first purchaser, or if it is installed after sale by a person other than the vehicle owner, care must be taken to insure that the photometric and visibility requirements of the standard for center high-mounted stop lamps continue to be met with the unloaded rack in place.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

January 13, 1986

Mr. Jeffrey R. Miller Chief Counsel US Department of Transportation 400 Seventh Street S.W. Washington, Washington D.C. 20590

Dear Mr. Miller:

The Highland Group is a US Manufacturer of Passenger Car Rear Deck Luggage Racks.

It has been rumored in the field that a deck - mounted luggage rack loaded with luggage may cause a violation of the center high-mounted stop lamp provisions of Motor Vehicle Safety Standard Number #108.

To alleviate potential problem in the field, any input you could provide in this matter would be greatly appreciated.

Sincerely,

THE HIGHLAND GROUP, INC.

Kevin Rossman Vice President - Sales & Marketing

KR/nc