Interpretation ID: nht89-1.64

TYPE: INTERPRETATION-NHTSA

DATE: 04/03/89

FROM: THOMAS C. GRAVENGOOD -- AGAPS PLASTICS INC

TO: NHTSA CHIEF CONSEL

TITLE: REF: FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 108 - HEATED SAFETY LIGHTS FOR VEHICLES DRIVEN IN WINTER WEATHER.

ATTACHMT: ATTACHED TO LETTER DATED 05/16/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS C. GRAVENGOOD; REDBOOK A33; STANDARD 108; ALSO ATTACHED TO LETTER DATED 08/11/89 FROM STEPHEN WOOD TO GEORGE VANSTRATEN

TEXT: PER MY TELEPHONE CONVERSATION WITH MR. TAYLOR VINSON ON FRIDAY, MARCH 31, 1989, PLEASE FIND LITERATURE, SAMPLES AND SPECS OF OUR NEW HEATED SAFETY LIGHTS/LENSES.

FOR THOSE WHO DRIVE IN THE SNOW STATES IT OFTEN BECOMES DIFFICULT OR IMPOSSIBLE TO SEE THE LIGHTS OF VEHICLES AHEAD AND BEHIND. THE HEATED SAFETY LIGHT ELIMINATES THE ICE AND SNOW BUILD-UP FORMING THE CRUST THAT BLOCKS OUT VEHICLE LIGHTS.

AT THIS POINT, HEATED SAFETY LIGHTS HAVE BEEN PURCHASED BY THE STATE OF MICHIGAN FOR USE ON HEAVY SNOW REMOVAL EQUIPMENT, SCHOOL DISTRICTS FOR SCHOOL BUS LIGHTS, AND OTHER PURCHASES BY SEMI TRAILER REPLACEMENT PARTS DEALERS. THE HEATED SAFETY LIGHTS HAVE PROVED VIABLE AND ARE PERFORMING AS ADVERTISED IN THE ENCLOSED BROCHURE. THE LIGHTS ARE REORDERING AND NEW ORDERS ARE COMING IN FROM A SMALL AD PLACED IN A TRUCK MAGAZINE.

AGAP'E PLASTICS HAS BEEN APPROACHED BY VAN STRATEN TO TAKE OVER THE ASSEMBLYING OF THIS LIGHT TO INCREASE THE PRODUCTION NUMBERS AND SALES. WE ARE IN THE PROCESS OF SETTING UP A MULTIPLE PRODUCTION SYSTEM, AND ARE WORKING ON A NATIONAL MARKETING PROG RAM THAT WILL PUT US IN TOUCH WITH CUSTOMERS IN TWO DIFFERENT SEGMENTS OF SALES.

ALL LIGHTS, LENSES, AND MATERIALS TO ASSEMBLE THE HEATED SAFETY LIGHTS HAVE ALREADY BEEN CERTIFIED AND PASSED THE MOTOR VEHICLE SAFETY STANDARD NO. 108. WE HAVE BEEN ADVISED BY THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION THAT THERE IS NO MOTOR VEHICLE SAFETY STANDARD NO. FOR HEATED SAFETY LIGHTS. IN ORDER FOR US TO DO BUSINESS AT THE O.E.M. LEVEL WE REQUIRE A LETTER OF APPROVAL FROM YOU TO US THAT WE MAY PASS ON TO OUR CUSTOMERS SO THEY MAY START ORDERING AND WE MAY START PRODUCING.

IF YOU HAVE ANY QUESTIONS, CONTACT TOM GRAVENGOOD OR TOM ALT. AT AGAP'E PLASTICS, 616/363-1191. WE ARE LOOKING FORWARD TO HEARING FROM YOU IN THE VERY NEAR FUTURE. THANK YOU.

SINCERELY,