ID: 9646

Martin M. Sackoff, Ph.D.
Executive Director of Laboratories
International Testing Laboratories
578-582 Market Street
Newark, NJ 07015-2913

Dear Dr. Sackoff:

This responds to your letter to this agency with reference to Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires.

Your specific question addressed S4.2.2.4, Tire strength, which states: "Each tire shall meet the requirements for minimum breaking energy specified in Table I when tested in accordance with S5.3." You asked for an interpretation of the term "breaking," whether it means a blowout of the tire or the breaking of the tire caused by the plunger used in the test specified in the standard.

The breaking energy test is a measure of the resistance of the tire to bruise or damage due to impact of the tire with road hazards. This agency tests such resistance in accordance with the procedures of S5.3, Tire strength, of the standard. In that test, a cylindrical steel plunger is forced perpendicularly into the tire rib at the rate of 2 inches per minute at five test points equally spaced around the circumference of the tire. The inch-pounds of force required to push the plunger into the tire is continuously monitored. As the plunger pushes into the tire, the resistance to the plunger force increases. That resistance requires ever- increasing force applied to the plunger to continue pushing it into the tire. Ultimately, one of two things will happen:

1. The plunger will push all the way to the rim; or

2. The tire cords, plies, innerliner, or other components of the tire will stretch, separate, crack or break so that the resistance pressure of the tire diminishes. The "breaking" of the tire at that point does not require an actual blow-out although, obviously, a blow-out would constitute a "breaking."

The plunger force is measured just prior to contact with the rim as in 1 above or just prior to the force reduction described in 2 above. The measured force is then combined with the penetration of the plunger into the tire as specified in S5.3.2.3 and S5.3.2.4 of the standard. The breaking energy value of the tire is then determined by computing the average of the values obtained at the five test locations on the tire. Table I, Appendix A of the standard specifies the minimum breaking energy of tires based on tire type, size, composition, and inflation pressure.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel ref:109 d:5/12/94

ID: nht94-5.41

DATE: May 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Martin M. Sackoff -- Executive Director Of Laboratories, International Testing Laboratories

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 2/7/94 FROM MARTIN M. SACKOFF TO NHTSA OFFICE OF CHIEF COUNCIL (OCC - 9646)

TEXT: Dear Dr. Sackoff:

This responds to your letter to this agency with reference to Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires.

Your specific question addressed S 4.2.2.4, Tire strength, which states: "Each tire shall meet the requirements for minimum breaking energy specified in Table I when tested in accordance with S 5.3." You asked for an interpretation of the term "breaking," whether it means a blowout of the tire or the breaking of the tire caused by the plunger used in the test specified in the standard.

The breaking energy test is a measure of the resistance of the tire to bruise or damage due to impact of the tire with road hazards. This agency tests such resistance in accordance with the procedures of S5.3, Tire strength, of the standard. In that test, a cylindrical steel plunger is forced perpendicularly into the tire rib at the rate of 2 inches per minute at five test points equally spaced around the circumference of the tire. The inch-pounds of force required to push the plunger into the tire is continuously monitored. As the plunger pushes into the tire, the resistance to the plunger force increases. That resistance requires ever-increasing force applied to the plunger to continue pushing it into the tire. Ultimately, one of two things will happen:

1. The plunger will push all the way to the rim; or

2. The tire cords, plies, innerliner, or other components of the tire will stretch, separate, crack or break so that the resistance pressure of the tire diminishes. The "breaking" of the tire at that point does not require an actual blow-out although, obviously, a blow-out would constitute a "breaking."

The plunger force is measured just prior to contact with the rim as in 1 above or just prior to the force reduction

2

described in 2 above. The measured force is then combined with the penetration of the plunger into the tire as specified in S5.3.2.3 and S5.3.2.4 of the standard. The breaking energy value of the tire is then determined by computing the average of the values obtained at the five test locations on the tire. Table I, Appendix A of the standard specifies the minimum breaking energy of tires based on tire type, size, composition, and inflation pressure.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

ID: aiam4470

"Dear Mr. Huber: This responds to your letter requesting a interpretation of Standard No. 101, Controls and Displays. You stated that you manufacture an electronic instrument cluster for use with van conversions and class 'A' motorhomes and other vehicles. The gauges are of a bar graph type, and associated with each graph is an icon or symbol to indicate the graph function. During normal operation, the icons are illuminated to the same light intensity as the graphs. You stated that as an added feature, the icons blink when, and only when, that function becomes critical or dangerous, such as for low fuel, high temperature, low oil pressure, and low battery. You stated that some of your customers have expressed concern about using your instrument cluster because it may not comply with Standard No. 101, and you requested a formal opinion. The issues raised by your letter are addressed below. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act), it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. The Vehicle Safety Act authorizes NHTSA to issue safety standards for new motor vehicles and new motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards set forth in 49 CFR Part 571. Manufacturers of motor vehicles must certify compliance of their products in accordance with Part 567, Certification. Persons altering a new vehicle prior to its first sale to a consumer are considered vehicle alterers under NHTSA's certification regulation. Part 567.7, Requirements for Persons who Alter Certified Vehicles, requires alterers to certify that the vehicle, as altered, complies with all applicable safety standards. Manufacturers, distributers, dealers, or motor vehicle repair businesses modifying a used vehicle are prohibited by section 108(a)(2)(A) of the Vehicle Safety Act from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Standard No. 101 (49 CFR Part 571.101) specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. The standard's requirements for displays are applicable only to vehicles with a gross vehicle weight rating of less than 10,000 pounds. See section S5. For these vehicles, the gauges identified in your letter (fuel, temperature, oil pressure, and electrical charge) are displays regulated by the standard. The primary issue raised by your letter is whether the identification of gauges may flash. As discussed below, Standard No. l0l does not prohibit such flashing. Section S5.3.3 states: S5.3.3(a) Means shall be provided for making controls, gauges, and the identification of those items visible to the driver under all driving conditions. (b) The means for providing the required visibility-- (l) Shall be adjustable, except as provided in S5.3.3(d), to provide at least two levels of brightness, one of which is barely discernible to a driver who has adopted to dark ambient roadway conditions. (2) May be operable manually or automatically, and (3) May have levels of brightness at which those items and their identification are not visible. (c) Effective September l, l989, if the level of brightness is adjusted by automatic means to a point where those items or their identification are not visible to the driver, a means shall be provided to enable the driver to restore visibility. (d) For a vehicle manufactured before September l, l989, the requirements of S5.3.3(b)(l) shall not apply to any gauge during the actuation of a telltale which shares a common light source with the gauge. Under section S5.3.3(a), means must be provided for making the identification of gauges, i.e., the icons or symbols in your design, visible to the driver under all driving conditions. The on-and-off cycling of the identification occurring during flashing would create momentary periods of time when the identification is not visible. However, it is our opinion that a flashing identification or other item is considered visible so long as it is visible during the on part of the cycle. This opinion is limited to the specific issue addressed above and does not constitute an opinion as to whether your electronic instrument cluster complies with Standard No. l0l. As you may know, several amendments were made to Standard No. l0l during l987. Enclosed for your information is a copy of the current standard. Sincerely, Erika Z. Jones Chief Counsel Enclosure /";

ID: 22525.ztv

Mr. Harold Holeman
C5 Creations
2 Renee Lane
Newark, DE 19711





Dear Mr. Holeman:

This is in reply to your email of December 26, 2000, asking for interpretations of Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices and Associated Equipment."

Your first question is whether "the standards as set forth in FMVSS 108 require that bumper bras or bumper masks have openings around the running lights, parking lights, turning signals, etc.?"

Standard No. 108 does not regulate bumper bras or masks per se. However, lighting equipment is required under Federal law to comply with all requirements of Standard No. 108 when accessory equipment such as bumper bras are installed by regulated persons, whether the equipment is installed as original equipment or aftermarket equipment. The one exception under Federal law is a bra or mask installed by the vehicle owner; if this creates a noncompliance with Standard No. 108, the owner is responsible under any applicable local laws rather than Federal law.

Your next question is "If the bra material is transparent and does not noticeably diminish the luminescence of the lights is the bra design within code without having cutouts for the lights?" Paragraph S7.8.5 prohibits "any styling ornament or other feature, such as a translucent cover or grille, in front of the lens" when the headlamps are activated. We view a transparent bra as an "other feature" and prohibited by Standard No. 108. Thus, a transparent bra could not be installed by a regulated person (i.e., manufacturer, distributor, dealer, or motor vehicle repair business) without violating Standard No. 108, but could be installed by the vehicle owner, provided that it does not violate local laws.

You then ask "Is there a test that should or can be performed to show that the intensity of the running lights is adequate even when covered by the bumper bra?" The photometric tests for each of the lamps covered by Standard No. 108 are essentially those of the Society of Automotive Engineers, which have been incorporated by reference in Standard No. 108. These are laboratory tests rather than tests conducted on the vehicle itself. They could be conducted with the transparent bra or mask material cut to fit the lens. Any diminution in light output must not result in photometric output falling below the minimum levels specified for test points in any individual standard.

Like you, we are not aware of any transparent bra or mask on the market. In general, we do not favor covering the lens of any lamp with other material. Dirt and grime may accumulate to the point that candela is reduced below the minimum specified in the standard. Further, it may not be easily removable by washing the cover.

Sincerely,

John Womack
Acting Chief Counsel

ref:108
d.4/19/01

ID: aiam0539

Dear Mr. Massey: This is in reply to your letter of September 12, 1972, regarding th application of S4.3 of Standard No. 207, Seating Systems, to an auxiliary folding seat installed in Brockway trucks.; As shown in your drawings and photographs, the seat faces forward an has a hinge at the rear of the lower cushion. An upward force at the front of the lower cushion will move the cushion upward and rearward until it presses against the seat back.; The intent of S4.3 is to reduce the forces acting on an occupant in a accident by preventing the seat or seat back from folding onto him. It does not appear from the material you have submitted that any motion of the lower seat cushion will impose such additional forces on an occupant. The folding action is therefore not of the type contemplated by the standard and no restraining device would be required for this seat.; Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: aiam0700

Dear Mr. McCamant: This is in reply to your letter of April 21, 1972, in which you reques clarification as to the application of the Tire Identification and Recordkeeping regulations (49 CFR Part 574) to your members under various circumstances described therein.; Generally persons other than tire manufacturers who have obligation under the Tire I.D. regulations are motor vehicle manufacturers and tire distributors and dealers. A person adding tires to a vehicle of which he is either an incomplete vehicle manufacturer, intermediate manufacturer, or final-stage manufacturer, as those terms are defined in 49 CFR 568.3, will be a vehicle manufacturer subject to the requirements of 574.10. Those persons adding tires as part of modifications to used vehicles will be tire dealers, and subject to the requirements of 574.8.; With respect to the three situations you list, in those cases where th tires have already been installed on the vehicle when your member receives it (Case No. 1), your member would not be adding tires to the vehicle and would not be responsible for compliance with the Tire I.D. requirements. In those cases where the tires are added or changed by an independent tire dealer, if the independent dealer is actually doing business with your member rather than with the owner of the vehicle, and if your member is an incomplete, intermediate, or final-stage manufacturer, he must comply with 574.10. If he does not fall within any of these categories he will be a tire dealer subject to 574.8. If the tire dealer is dealing independently with the owner of the vehicle, your member will not be the party adding tires to the vehicle, and will not be subject to the requirements. With regard to the situation where your member puts tires on a frame or vehicle as part of a package deal (Case No. 3), if he is either an incomplete vehicle, intermediate or final-stage manufacturer he will be required to comply with the requirements of 574.10. If he does not fall within these categories, he will be a tire dealer and subject to section 574.8.; Assuming your member must record the name of the first purchaser as manufacturer or dealer, you have asked whether he may use the name of the dealer to whom he delivers the vehicle as the first purchaser, when that is the case, as he frequently does not know the name of the first purchaser for a purpose other than resale. You refer to our March 14, 1972, letter to you in which we stated that a dealer's name could be used in meeting the 'Owner's List' requirement of the Defect Reports regulations (49 CFR Part 573) when the name of the dealer was the only name which the manufacturer had. For the purposes of the Tire I.D. requirements, the manufacturer must obtain and use the name of the actual purchaser for a purpose other than resale. It is not sufficient under this requirement for the name of the dealer to be used. Section 113(f) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1402(f), which became effective November 18, 1970, provides that.(sic) 'Every manufacturer of motor vehicles or tires shall maintain records of the names and addresses of the first purchaser (other than a dealer or distributor) of motor vehicles or tires produced by that manufacturer.' In our view this provision requires the manufacturer of a multi-stage vehicle who adds the tires to the vehicle to obtain the names of such purchasers, even if the names must be obtained from dealers. Our letter of March 14 should not be read to absolve your members who are such manufacturers from meeting this requirement. What that letter allows is simply that in those cases where manufacturers have not, at the time they must compile an owner list, obtained the names of first purchasers, they may use the name of the dealer and not be in violation of the 'Owner's List' requirement. This may be done, however, only until they can obtain the actual first purchaser's name. We regret that this point was not made clear in our March 14 letter, and that letter is hereby modified in this regard.; Concerning your question as to the conditions under which automotiv wholesalers and warehouse distributors must keep Tire Identification records, if the automotive wholesaler or warehouse distributor is not selling tires directly to the user of the vehicle he need only ensure that the dealer or distributor to whom he sells the tires has a means of recording the required information so that it may be forwarded to the tire manufacturer (section 574.8(c)). In the event the automotive wholesaler or warehouse distributor sells tires to a user, then he must record the information specified in S 574.7(a) and forward that information to the tire manufacturer.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: aiam4925

"Dear Mr. Lewandoski: This responds to your letter of July 9, l99l, t Robert Hellmuth of this agency, regarding an apparent conflict between an interpretation furnished you by this Office on May 23 of this year, and a Memorandum of the California Highway Patrol (CHP) dated May 30, 1991. The subject is whether the Tekonsha Voyager and Commander electronic brake controls ('the Brake Control') are permitted under Motor Vehicle Safety Standard No. 108. The Brake Control incorporates a 'manual override' slide bar that activates the trailer brakes without a corresponding activation of the trailer stop lamps. On May 23, we responded to your question whether activation of 'the trailer brakes and non-activation of the tow vehicle/trailer stop lamps comply' with Standard No. 108. We informed you that Standard No. l08 does not so permit, and that, because the Brake Control 'applies the service brakes to diminish vehicle speed,' the stop lamps are required by Standard No. 108 to be activated. However, on May 30, CHP issued Management Memorandum No. 91-80 stating that this agency had issued a ruling that the Brake Control was 'legal' under the preemption authority of l5 U.S.C. 1392(d), and that CHP personnel should consider the device to be in compliance with State requirements. You have asked for a clarification of the apparent conflict between our May 23, 1991 interpretation and the CHP memorandum. The Patrol informs us that its Memorandum was based upon an interpretation that this office furnished on September 10, l990, to Lawrence F. Henneberger. Describing the Tekonsha Commander as a device which would allow the driver of a tractor-trailer combination 'to use the hand control to override the trailer brakes in an emergency mode to control swaying,' Mr. Henneberger had stated last year that California had taken the position that the vehicle's stop lamps must be activated when the Brake Control is used, 'even though the service brakes are not applied at the time.' It appeared to us from Mr. Henneberger's statements that the purpose of the Brake Control was 'to control trailer sway and not 'to stop or diminish speed by braking.'' The basis for California's position was its interpretation of Section 24603(f) of the California Vehicle Code which states, in pertinent part, that stoplamps shall be activated upon application of the hand control head for electric brakes. We responded to Mr. Henneberger in our September 1990 letter that the California requirement conflicted with the requirement in Standard No. l08 that stop lamps be activated upon application of the service brakes, and that therefore, under the preemption clause of l5 U.S.C. 1392(d), Section 24603(f) was preempted 'to the extent that it may be read as requiring stop lamps to be activated on motor vehicles equipped with the Commander Electronic Brake Control, when the Control is hand activated in an emergency mode to provide sway control.' We have reviewed the interpretations of September 10, 1990, and May 23, l991, as you have requested, and we have concluded that our interpretation letter to Mr. Henneberger was in error. Although Mr. Henneberger informed us that the Brake Control 'does not involve application of the vehicle's service brakes' (Henneberger letter, June 22, l990, page 2, there are also three similar representations on page 4), the Tekonsha product literature that you supplied us clearly states that 'The Voyager will not apply the trailer brakes unless the manual override slide bar is applied.' (Item 5 under 'Important Facts to Remember'), demonstrating that application of the Brake Control results in application of the trailer's service brakes. We have talked with Sergeant Cox of the California Highway Patrol about the operation of the Brake Control. We understand that operation of the Brake Control sends an electric impulse to the trailer brakes without going through the main tractor/trailer brake actuation system. The activation of the trailer brakes without a simultaneous activation of the tractor brakes allows the tractor to proceed with undiminished speed in order to take the slack out of the connector by increasing the distance between it and the trailer, which has slowed due to the activity of the electronic brake control, and thereby reduce the sway of the trailer. This information about the Brake Control is the basis for our reconsideration of the interpretation of September 10, 1990. Although use of the Brake Control does not involve application of the 'vehicle's service brakes' through the service brake control, it nevertheless does 'apply the trailer brakes' as that phrase is used by Tekonsha in its product literature. Although the immediate intent of the driver may be to control sway, that intent is realized by creating a differential in speeds between towing and towed vehicles. That differential is created, not by increasing the speed of the towing vehicle, but by diminishing the speed of the towed vehicle through braking. As we noted in the September l0 letter, a stop lamp is defined in part as a lamp that indicates the intent of the driver to diminish speed by braking. We therefore find that Standard No. l08 and 15 U.S.C. 1392(d) do not preempt Section 24603(f) of the California Vehicle Code. We confirm our interpretation of May 23, that installation of the Tekonsha systems, under the conditions and by the persons therein described, appear to violate Standard No. 108 and the National Traffic and Motor Vehicle Safety Device. Our letters to both you and Mr. Henneberger may have left the impression that operation of the Brake Control on the brakes of the towed vehicle also requires activation of the stop lamps of the towing vehicle. Sgt. Cox has clarified that the Brake Control activates only the brakes of the towed vehicle, not the towing one. Consequently, Standard No. l08 would not require activation of the towing vehicle's stop lamps when the Brake Control alone is used to apply the brakes of the towed vehicle to diminish sway. A copy of this letter is being provided the Department of California Highway Patrol, and Lawrence Henneberger, attorney for Tekonsha. Sincerely, Paul Jackson Rice Chief Counsel cc: Lawrence F. Henneberger, Esq. Sgt. Larry Cox, CHP";

ID: 10206

Mr. Gene Byrd
Anderson Technology
17 Ross St.
Jamestown, NY 14702-0759

Dear Mr. Byrd:

This responds to your letter to former Chief Counsel Pansel

Enclosure ref:222 d:8/19/95 losure ref: 222 NCC-20:MVersailles:mar:62992:7/28/94 U:\NCC20\INTERP\222\10195.MLV cc: NCC-10, Subj/Chron, NCC-20 MV, NRM-01, NEF-01 Interps: 222, Redbook (2)stions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:VSA d:8/18/94 makes inoperative" compliance with any safety standard.

NHTSA is concerned that the "Belly Safe" could be used in a way that adversely affects crash forces on the occupant. Standard No. 208 includes requirements that have the effect of ensuring that the lap and shoulder belts distribute the crash forces to the occupant's skeletal structure, a part of the body that can better withstand the forces. For example, Standard No. 208 requires the shoulder belt and the lap belt to intersect off of the abdominal area. The "Belly Safe" places an object between the legs of the occupant. This change in the distribution of crash forces could have serious safety implications for the wearer of the belt.

There are other concerns about the "Belly Safe." The realigning of the lap belt through the "Belly Safe" could increase the amount of webbing in the belt system. If the straps which attach around the back of the seat or the Velcro holding the lap belt are unable to withstand the forces of a crash, there would be excessive slack in the lap belt. Slack in the lap belt would increase the risk of the occupant sliding under the lap belt (submarining) and slack in the belt system generally introduces higher crash forces, both of which would increase the risk of injury. In addition, should a non-pregnant occupant use the "Belly Safe," the device could do more harm than good.

I have enclosed a consumer information sheet titled "Pregnancy: Protecting Your Unborn Child in a Car." This sheet explains that the lap belt should be placed low, across the hips and over the upper thighs. If a woman takes the time to adjust the belt as recommended (an action also needed to install the "Belly Safe"), NHTSA is unaware of any need for a device to keep the lap belt in this position.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:208 d:7/14/94 he address provided in the enclosed information shted; however, the substantive requirements described in the sheet have not changed.

ID: nht89-3.24

TYPE: INTERPRETATION-NHTSA

DATE: 10/31/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: MARK F. HOLMES

TITLE: NONE

ATTACHMT: LETTER DATED 09/28/89 FROM MARK F. HOLMES TO STEVE WOOD -- NHTSA; OCC 3980; LETTER DATED 09/28/89 FROM MARK F. HOLMES TO STEVE WOOD -- NHTSA

TEXT: Dear Mr. Holmes:

This is in reply to your letter of September 28, 1989, with respect to two lighting devices known as the Strobalarm and the Spotlight Alarm. You are interested in selling these devices in the aftermarket, and have asked whether they would be in violatio n of any of the standards and regulations of this agency.

These devices are "designed to be used only when a vehicle is parked or broken down." As we understand your letter and the materials you enclosed, both devices can be incorporated into existing alarm systems, to indicate when an attempted theft is in pro gress. The "locator" feature of the devices allows activation from a distance of 400 feet, enabling an approaching owner to easily identify his vehicle. With the use of a pink colored lens, the Strobalarm is intended to serve as an "emergency distress flare." You have enclosed two color renderings of these devices, titled "Interior/Strobe Alarm Light," and "Alarm Strobe Light Collision Avoidance Light."

The Federal law and regulation that must be considered to answer your question are the National Traffic and Motor Vehicle Safety Act (Title 15, United States Code, Sections 1381 and following), and Federal Motor Vehicle Safety Standard No. 108 Lamps, Ref lective Devices and Associated Equipment (Title 49, Code of Federal Regulations, Section 571.108), and Standard No. 111 Rearview Mirrors (49 CFR 571.111). Under Section 1397(a)(2)(A) of the Act, a manufacturer, distributor, dealer, or motor vehicle repa ir business may not render inoperative, in whole or in part, any item of equipment installed in accordance with a Federal motor vehicle safety standard. You will note that this prohibition does not extend to the vehicle owner.

Thus, the question to be addressed is whether the installation of either device by a manufacturer, distributor, dealer, or motor vehicle repair business would affect the performance of required safety equipment. The "Interior Strobe/Alarm Light" appears intended as a "dome" light, mounted centrally on the headliner above the passenger seats. In this position it has the potential to affect the field of view of the inside rear view

mirror required by Standard No. 111, as prescribed by paragraph S5.1.1 (copy enclosed). If the field of view is not met, an outside rearview mirror must be provided on the passenger side. You have not provided the dimensions of this device, and we are unable to advise you further. Other than this cautionary note, the "Interior Strobe/Alarm Light" does not appear affected by the laws and regulations of this agency. It would, however, be subject to state and local laws where it is sold and used. We a re unable to advise you on these, and suggest you contact the American Association of Motor Vehicle Administrators (AAMVA) for an opinion. Its address is 4600 Wilson Boulevard, Arlington, VA 22203.

The "Alarm Strobe Light Collision Avoidance Light" raises another consideration. The collision avoidance portion of the lamp appears intended to serve as a center highmounted stop lamp. Under paragraph S5.4 of Standard No. 108, the center lamp may not b e combined with any other lamp or reflective device. Thus, removal of an original equipment center lamp and substitution of your device by a person other than the vehicle owner would be regarded as partially rendering inoperative the original safety equ ipment, even if your device complied with all other requirements for the center lamp. The center lamp has been required on all passenger cars manufactured on or after September 1, 1985.

The restriction does not apply, of course, to installation on passenger cars manufactured before September 1, 1985, or other types of motor vehicles regardless of date of manufacture. Consideration must still be given, however, to continued compliance w ith Standard No. 111, and to whether any state specifications exist covering aftermarket center stop lamps. Again, the AAMVA may be able to help you.

I hope that this information is useful to you.

Sincerely,

ID: aiam2720

Dear Mr. Iinuma: This responds to your October 4, 1977 letter asking whether Standar No. 118 *Power-Operated Window Systems*, prohibits the operation of power windows when the ignition key is in the 'Accessories' position.; Standard No. 118 requires only that power windows be inoperable whe the key is in the 'off' position or is removes from the lock, with certain exceptions outlines in S3. It is permissible for the windows to operate normally when the key is in the 'Accessories' position.; Sincerely, Joseph J. Levin, Jr., Chief Counsel