Interpretation ID: nht89-2.12

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: BOB SANDBLOM -- BOOKLAND

TITLE: NONE

ATTACHMT: LETTER DATED 05/18/89 FROM BOB SANDBLOM TO DEPARTMENT OF TRANSPORTATION; OCC 3584; LETTER DATED 09/03/87 FROM ERIKA Z. JONES -- NHTSA TO DAVID M. ROMANSKY; STANDARD 108

TEXT: Dear Mr. Sandblom:

Thank you for your letter of May 18, 1989, addressed to the Department, calling our attention to a dealer practice of placing overlays on the center of highmounted stop lamps.

We have received a number of inquiries about this subject, and I enclose a representative response. You are correct that it is not legal for a dealer to create a noncompliance, but you will see from the letter enclosed that the practice is not in and of itself illegal provided that the lamp continues to meet the rather technical requirements of the standard after the overlay is required.

We appreciate your interest in motor vehicle safety, and for taking the time to write us.

Sincerely,

ENCLOSURE