United States Department of TransportationInterpretation ID: 0004
Member, United States House of
Representatives
5617 Liberty Fairfield Road
Hamilton, Ohio 45011
Dear Congressman Boehner:
This responds to your letter of April 7, 1994, to the Department of Transportation (DOT) on behalf of your constituents, John Cail Sr. and James Lipps of Eaton.
Messrs. Cail and Lipps have requested your assistance in obtaining DOT "approval and color code designation" for their "Life Lites" system. This is a stop lamp system consisting of two 18-inch long 1/2-inch wide devices intended to be mounted on the front of a vehicle alongside the windshield pillars, to emit a light of either purple or coral. The system is activated with the rear stop lamps when the brakes are applied, and it is intended to warn observers to the front of a vehicle that the vehicle is braking. It "could be mounted to most existing vehicles and could be readily incorporated into new car designs."
The National Highway Traffic Safety Administration (NHTSA)is the component of DOT that is responsible for motor vehicle safety under the National Traffic and Motor Vehicle Safety Act. The Act does not authorize NHTSA to "approve" or disapprove safety inventions such as Life Lites. We do advise, however, whether such inventions are permitted under the Act and applicable regulations such as the Federal motor vehicle safety standards. The fact that a device may be permitted under NHTSA laws must not be interpreted as our approval or endorsement of it.
The standard that applies to motor vehicle lighting is Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Life Lites emitting either color may be installed as original equipment by the manufacturer, distributor, or dealer at the time a vehicle is sold to its first purchaser provided that it does not impair the effectiveness of any of the frontal lighting equipment required by Standard No. 108 such as headlamps and turn signals. The materials you enclosed show a color closeup newspaper photo of a Life Lite
in operation; its relatively low output does not appear sufficient to impair headlamp effectiveness. There would be concern, however, if it were to distract attention from an operating turn signal and, in this sense, impair its effectiveness. However, the responsibility for determining whether supplemental original lighting equipment impairs the effectiveness of the required lighting equipment rests with the installer, and NHTSA will not question this determination unless it appears clearly erroneous.
Life Lites that are sold in the aftermarket and intended for vehicles in use, are prohibited by the Act if their installation by a manufacturer, distributor, dealer, or motor vehicle repair business "knowingly renders inoperative, in whole or part" the required motor vehicle lighting equipment. Though the words are different between the Act and Standard No. 108, in this instance we would equate partial inoperability with impairment of effectiveness and the same considerations would apply.
However, the Act does not prohibit vehicle owners under any circumstances from installing Life Lites themselves if they are able to do so. But the legality of Life Lites of either color and under any scenario remains subject to the laws of any State in which the device is operated. We are unable to advise your constituents of the laws of the individual States, and suggest that they write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.
Sincerely,
John Womack Acting Chief Counsel
cc: Washington Office
re:108#VSA d:6/2/94