Interpretation ID: 1983-3.18
TYPE: INTERPRETATION-NHTSA
DATE: 11/03/83
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Mr. Steve Lampeas
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Steve Lampeas: 117 Aldershot Lane Manhasset, New York 11030
Dear Mr. Lampeas:
This is in reply to your letter of October 13, 1983, concerning the legality under Federal laws of your patented device, the "Trunk Truck." It appears from the material you enclosed that the device extends in twin booms from the rear of the car, and that a stop lamp or taillamp is mounted at the end of each boom (you refer to it as a "natural extension" of these lamps).
Under the National Traffic and Motor Vehicle Safety Act, no person (except the vehicle owner) may modify a vehicle so that equipment that is on the vehicle pursuant to a Federal motor vehicle safety standard is "rendered inoperative in whole or in part." Therefore, you must assure yourself that all requirements of Federal Motor Vehicle Safety Standard No. 108 continue to be met with respect to rear lighting. This would include not only the lamps at the end of the booms, but those remaining on the car. In addition to stop lamps and taillamps, rear lighting includes, turn signal lamps, back up lamps, and license plate lamps. As on other load-bearing vehicles, such as boat trailers, these lamps should continue to be visible even with a load installed.
You should also ask the States whether such a device is legal. States have jurisdiction over the use of motor vehicles within their borders.
Sincerely,
Frank Berndt Chief Counsel
October 13, 1983
Mr.Frank Berndt Chief Council of National Highway Traffic Safety Administration 400 7th Street South West Washington D.C. 20590
RE: Trunk Truck
Dear Mr. Frank Berndt:
As per my telephone conversation today with Roger Fairchild, I am enclosing in this letter and sending to you a description and illustration of the Trunk Truck, which is a new patented devise that I have invented.
Before I go into production of this item I want to check with your legal department to be sure that there are no laws that the federal level that my be violated or any safety test that may be required, when this item is attached to a motor vehicle and is in use.
I believe your office has jurisdiction in this matter and would very much appreciate an early opinion and response.
Sincerely,
Steve Lampeas
TRUNK TRUCK
Need to move something quickly? It can be done with a Trunk Truck.
With this new patented device, you can transform your family car in minutes into a van, truck, or trailer and after you have moved your items you can change it back to your family car.
The Trunk truck is a telescoping, self adjusting, precision designed, light weight, high tensile aluminum alloy device, ready for instant use. It is a natural extension of the tail lights and breaking lights of your car. It is road worthy, stable and safe to use.
The Trunk Truck is an inexpensive way to move almost anything. It can be used by merchants, campers, outdoor vendors, house owners, and many others.
This patented device is highly versatile, proving stretch space not thought possible before, to take and carry a variety of items for the occasional or frequent moving job you map have.
The Trunk Truck will free the active man, from the dependency of a second car, van, truck, or trailer.
There will be no further need for additional garage space, license plates, insurances or inspection stickers and registration fees.
Its user are limitless. For example: Taxi Cab Fleet owners can use the Trunk Truck as the start of a new line of moving services.
With a medium sized car, you can expect to have a loading area of 30 square feet, a loading volume of 90 cubic ft. and an approximate weight load of 600 lbs.
The Trunk Truck can be installed easily and at a moderate price in your foreign or domestic car, out of the way inside your trunk.
For further information on the Trunk Truck, contact Lampeas Assoc. at 117 Aldershot Lane Manhasset L.I. N.Y. 11030
Trunk Truck Transform your car into a Van, Truck or Trailer in minutes
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