Interpretation ID: 20513.ztv
Mr. Gary D. Weintraub
185 East 85th St.
New York, NY 10028
Dear Mr. Weintraub:
This is in reply to your letter of August 9, 1999, asking about the legality of front "brake" lamp systems.
I enclose copies of two notices that we published in the Federal Register in December 1996, (61 FR 65510) and November 1998 (63 FR 59482) on supplementary vehicle lighting systems, including, specifically, front "brake" lamp systems (see discussions at 65515, and 59484 and 59486).
In response to our December 1996, request for comments, Volvo commented that we should not prohibit front "brake" lamps. As we explained in the November 1998 response to the comments (at 59484), front "brake" lamps are prohibited only if they impair the effectiveness of front lighting equipment required under Federal law, and that "assuming front 'brake' lamps were implemented so as not to interfere with the effectiveness of required front lighting equipment, front brake lamps are permitted to be installed on vehicles now, without any changes to the [U.S. Federal motor vehicle lighting standard]."
If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263).
Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:108
d.10/21/99