Interpretation ID: nht94-4.75

TYPE: INTERPRETATION-NHTSA

DATE: November 2, 1994

FROM: John Sheppard -- Sales and Marketing Manager, Reflexite Canada, Inc.

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO JOHN SHEPPARD (A42; REDBOOK 2; STD. 108)

TEXT: As a manufacturer of retro-reflective sheeting that meets the requirements for "DOT-C2" material as specified in N.H.T.S.A.'s final rule, 49 CFR, Part 57, Docket #80-9, we request an official ruling on the following proposal.

Use of the material outlined below, (sample enclosed) on the rear of vehicles currently required to meet the requirements of the aforementioned regulation.

Material: - Reflexite Conspicuity Material,

- Alternating red and silver strips oriented at a 45 degrees angle to the edge of the roll.

- Widths of rolls to be either 6" or 8".

- Rolls will not have "DOT-C2" marking.

The specific question is as follows:

Could the above mentioned material be applied to the lower edge of the vehicle's rear doors as a compliant substitute for the 2" "block pattern" material currently being used? This alternative would have a great deal more retro-reflective surface are a.

Your attention to this request would be greatly appreciated.