Interpretation ID: aiam4378
President
Atract Ad
3400 Hwy 427
Sanford
FL 32771;
Dear Mr. Romansky: This is in reply to your letter of August 11, 1987 asking for ou 'evaluation and comments' on your proposed product. This product is an adhesive label that is applied to the center highmounted stop lamp. When the brakes are applied the words 'buckle-up' become visible to the driver of the car behind.; Our comments relate to the acceptability of your product under th National Traffic and Motor Vehicle Safety Act and Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, and its relationship to State laws. The simplicity of the decal is such that it may be readily applied by anyone with no special expertise or tools. There will be no violation of the Act if the decal is applied by the vehicle owner. However, a vehicle in use is subject to the laws of each State in which it is registered or operated. We are not familiar with State laws governing partial obscuration of the center lamp. We suggest you write the American Association of Motor Vehicle Administrators, 1201 Connecticut Ave. N.W., Washington, D.C. 20036 for further information. There is at least the theoretical possibility that it may raise a question of liability, or provide a defense, in accident suits involving rear end collisions.; Questions of compliance would be raised were the decal applied by moto vehicle manufacturers, dealers, distributors, or repair businesses, either before or after sale of the vehicle. In essence, a new vehicle must comply with all applicable Federal motor vehicle safety standards at the time of its first sale, and the persons listed above must do nothing during the life of the car to affect the compliance of a device installed in accordance with a safety standard. If the decal reduces the effective projected luminous area of a lamp to less than 4 1/2 square inches, interferes with light output at any of 13 specified photometric test points, or renders the signal not visible to the rear through a horizontal angle from 45 degrees to the left to 45 degrees to the right of the longitudinal axis of the vehicle, the lamp will not conform. A person creating a noncompliance may be subject to a civil penalty of up to $1000 for each violation.; If you have any further questions we will be pleased to answer them. Sincerely, Erika Z. Jones, Chief Counsel