Interpretation ID: aiam4276
100 Lefferts Ave. 4D
Brooklyn
NY 11225;
Dear Mr. Doerr: This is in reply to your letter of December 12, 1986, to Secretary Dol on your 'Safety Light Warning System.' You have asked if your system 'could legally be implemented' and for advice 'how I may go about marketing this system.'; The patent drawing of your device depicts a light bar mounted in th rear window area with a green lamp in the center flanked by amber lamps, with two red lamps at the end. This system would be acceptable neither as original equipment on passenger cars, nor as replacement equipment on passenger cars manufactured on or after September 1, 1985. As of that date, Federal Motor Vehicle Safety Standard No. 108 requires passenger cars to be manufactured with a red stop lamp in the approximate location of your green lamp. There is no Federal prohibition against offering the system in the aftermarket for retrofitting on passenger cars manufactured before September 1, 1985, but the system would be subject to the laws of each State in which it would be sold or used. I understand that Oregon and California allow green-amber-red deceleration warning systems when the lamps are mounted on the rear of the car, but restrictions may exist as to their mounting in a vehicle's interior.; I hope this information is useful to you. Sincerely, Erika Z. Jones, Chief Counsel