Interpretation ID: 86-3.4

TYPE: INTERPRETATION-NHTSA

DATE: 05/01/86

FROM: RUDY VALDEZ -- PRODUCT MANAGER MR GASKET COMPANY

TO: NAT. HIGHWAY TRAFFIC SAFETY ADMINISTRATION OFFICE OF CHIEF COUNCIL

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/23/86 EST FROM ERIKA Z. JONES -- NHTSA TO RUDY VALDEZ, REDBOOK A29, STANDARD 108, AFTERMARKET DECORATIVE LIGHT

TEXT: Dear Sirs:

We are a company which manufactures and sells products for the Automotive Aftermarket. We are currently developing a product for this market and need an interpretation concerning its' legality. The unit in question is a splash guard designed for automobiles and light trucks. When the running lights are turned on, a light in the splash guard will light up at the same time. Our concern is in the location of the light. Although purely decorative, would placing a light in this area violate any state or federal standards or codes? With this letter, you will find a crude lay out of the instructions for this item. This will hopefully give you a clear idea of what this unit will be doing. Any help that you can give us with this product would be helpful.

Secondly, any information you can give us related to the collision avoidance light will be a great help. We are most interested in the direction your department is going in relation with the aftermarket.

We have seen a number of these units which do not appear to meet the federal regulation related to this item. Will the D.O.T. regulation for new automobiles soon pertain to those already on the road. If the D.O.T. regulation will not be required for vehicles already on the road, how closely will the retro fit unit need to be?

Clarification on these points will be helpful to both us and our customers. We thank you in advance for any help you can give us in both of these matters. If there is any problems that need clarification, please feel free to contact me.

Sincerely