Interpretation ID: aiam0484

Mr. Harold T. Halfpenny, Halfpenny, Hahn & Roche, 111 West Washington Street, Chicago, IL, 60602; Mr. Harold T. Halfpenny
Halfpenny
Hahn & Roche
111 West Washington Street
Chicago
IL
60602;

Dear Mr. Halfpenny: This is in reply to your letters of October 18, 1971, and November 1 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, concerning the 'Panic-Stop' signal system from Donel Corporation.; You are correct in your interpretation that Federal Motor Vehicl Safety Standard No. 108 is not applicable to the 'Panic-Stop' system when this system is not installed on motor vehicles as original equipment. The motor vehicle laws and regulations of the individual States, are, however, applicable to the 'Panic-Stop' system when sold and used as aftermarket equipment.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;