Interpretation ID: nht78-2.20

DATE: 05/18/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Mohs Seaplane Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 5, 1978, asking "what is necessary for the rewriting of [Motor Vehicle Safety Standard No.] 108 to include my . . . system for vehicle identification." As you have described this reflective device, it is a polyvinyl extrusion in which is placed polyester tape which "becomes a continuous reflector down the side of a vehicle - amber toward the front, red on the rear half of the vehicle and red across the back." You state that in your experimental installation you are "retaining the 3" spot reflectors as required in Standard 108."

If your material conforms to Federal Specification L-S-300 and, as used on the vehicle, meets the performance standards in Table 1 of SAE Standard J594d, "Reflex Reflectors," March 1967, it could be used as the front and rear reflex reflectors required by Standard No. 108. However, if it does not meet this specification, Standard No. 108 would not prohibit the sale and installation of your system as original equipment, or as an aftermarket accessory, provided it is supplementary to the side and rear reflectors required by Standard No. 108. Thus, no Federal "approval" of your system is required. A change in Standard No. 108 is required only if you believe your system should be mandatory on all motor vehicles. In the event you wish to petition for such an amendment of Standard No. 108, I enclose a copy of our rulemaking procedures.

YOURS TRULY,

Mohs Seaplane Corporation

May 5, 1978

Chief Consul, NHTSA

Dear Sir,

I was advised by Mr. Carderelli of the American Association of Motor Vehicle Administrators that I should request approval of a new reflective device I have for motor vehicles which consists of a poly-vinyl extrusion in which is placed polyester metallic tape and into which is slid computer designed and computer milled reflectors so the final result becomes a continuous reflector down the side of a vehicle -- amber toward the front, red on the rear half of the vehicle and red across the back.

This invention is an adaptation of the very advanced reflectors used in the space age to assist solar cells in their recharging efforts on satelites, and adaptation to motor vehicle use from the railroad crossing buck use portrayed in Governor Martin Schreiber's Safety Reporter enclosed (please note page 2). We are just beginning the installation on 50 semi-trailers here in Madison as an accessory item and retaining the 3" spot reflectors as required in standard 108. Our photometric result is superior to acrylic reflectors used in the past and reflective sheeting, etc.

Please let me know what is necessary for the rewriting of 108 to include my (I believe) superior system and safer system for vehicle identification. Of course we have many other uses for something that performs as to other reflectors as the super ball does to a conventional ball. We have a patent pending number. Piers, gunnels of boats, mail box posts, railway crossing gates, loading docks, etc. have been experimented with.

Last September I saw Mr. Marx Elliott in your building on this same matter and also have talked with Mr. Bill Eason. Since sales are just now really taking off government approval is essential and certainly desired. In the interests of safety -- all selfish profit motives aside -- I think we have something of interest here. I will gladly send samples if you so request to above address.

Please also send proceedures to follow to above address.

Bruce Baldwin Mohs, Pres. MOHS SEAPLANE CORPORATION

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