ID: aiam0831

Gentlemen: Your letter of August 8 and your follow-up letter of August 22 to Mr Francis Armstrong, Director, Office of Standards Enforcement, concerning the lighting requirements for motor-driven cycles, were forwarded to this Office for consideration and reply.; The lighting requirements specified in Federal Motor Vehicle Safet Standard No. 108 are identical for a motorcycle and a motor-driven cycle (except for headlamps, see SAE J584 April 1964), because the latter is defined in Part 571 of the standards as 'a motorcycle with a motor that produces 5- brake horsepower or less.'; In addition, the answers to your specific questions follow -- >>>1. Must the stop-light of a motor-driven cycle be operated by han and foot brake?; *Answer* - Yes. Paragraph S4.5.4 of FMVSS No. 108 requires the stop lamps on eac vehicle to be activated upon application of the service brakes, and since both the hand and foot brakes are service brakes, the application of either must activate the stop lamps.; 2. Does there exist any regulations concerning the light intensity o the brake-light?; *Answer* - Yes. Currently stop lamps must conform to the photometric requirement specified in SAE Standard J575d. Paragraph S4.1.1.6 of FMVSS No. 108 also requires that vehicles manufactured on or after January 1, 1973, be equipped with stop lamps meeting the candlepower requirements for Class A turn signal lamps in SAE J575d.; 3. Are turn signals prescribed? *Answer* - Yes. Class B turn signal lamps (see SAE J575d) are required o motorcycles manufactured on or after January 1, 1973, and should be mounted as specified in Table IV of FMVSS No. 108 (copy enclosed for your information).; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: nht79-1.14

DATE: 10/04/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Grote Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT:

October 4, 1979

Mr. C. J. Newman Vice President, Engineering The Grote Manufacturing Company State Rt. 7 - P.O. Box 766 Madison, Indiana 47250

Dear Mr. Newman:

This in reply to your letter of August 23, 1979, to the former Chief Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp "meets the intent" of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.

You have quoted paragraph 3.4 of SAE Standard J588e, September 1970, which states "the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles." It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.

We would also like to observe that since the side marker signal uses the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.

Sincerely,

Frank Berndt Chief Counsel

Mr. Taylor Vinson Office of the Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATlON 400 Seventh Street S W WASHINGTON DC 20590

September 24, 1979

Dear Mr. Vinson

Request for Interpretation

In the case of a motorcycle headlamp, Table III of FMVSS 108 cites SAE J584, which in turn specifies that for photometric tests, the "bulb or unit shall be operated at its rated voltage during the test."

Where the material bulb is an H1, H2, H3 or H4 halogen bulb that bears the E-mark signifying that it is in compliance with E/ECE/TRANS/505/Rev.1/Add.36, that is to say in compliance with Regulation 37 of the Geneva Agreement of 20 March 1958 as adopted by the general European governments, is the rated voltage required by SAE J584 the same rated voltage of ECE Regulation 37?

Yours sincerely

H J T YOUNG Vice President - Technical Affairs

E/ECE/324 ) E/ECE/TRANS/505 )Rev.1/Add.36 Regulation No. 37 Annex 1 page 21/22

CATEGORY H4 Sheet H4/2

Characteristics

Lamps of normal production Standard lamps

*Insert chart here

1/ Where a yellow outer bulb is used, "m" and "n" denote the maximum dimensions of this bulb; where there is no outer bulb "m" denotes the maximum length of the lamp.

2/ It must be possible to insert the lamp into a cylinder of diameter "s" concentric with the reference axis and limited at one end by a plane parallel to and 20 mm distant from the reference plane and at the other end by a hemisphere of radius S/2.

3/ The obscuration must extend at least as far as the cylindrical part of the bulb. It must also overlap the internal shield when the latter is viewed in a direction perpendicular to the reference axis. The effect sought by obscuration may also be achieved by other means.

4/ The values indicated in the left-hand column relate to the driving beam. Those indicated in the right-hand column relate to the passing beam.

August 23, 1979

U. S. Department of Transportation NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attn: Mr. J. J. Levin, Jr. Chief Counsel

Dear Sir:

We are considering certain revisions to our line of front double-faced pedestal mount turn signal lamps. Before making any commitment to our customers or before making any tool changes, we need your opinion as to whether the lamp meets the requirements of Federal Motor Vehicle Safety Standard 108.

In the past, double-faced turn signal lamps having side marker devices have normally been manufactured with two bulbs -- a 1156 or 32 candle power bulb functioning as the turn signal system, and a 2 or 3 candle power bulb functioning as the side marker device. In this case, having an yellow lens to the front and a red lens to the rear. Our proposed change is to use one 1157 bulb, dual function 32 - 3 candle power filaments where the 32 candle power filament is used as the turn signal function and the 3 candle power is used as the side marker device. In order to do this, a yellow lens to the front, yellow lens to the rear is required and also the baffling inside of the double-faced lamp has to be reduced in order to meet the side marker requirements. With this particular design, all three lenses -- the lens to the front, to the rear and to the side -- function as part of the side marker device.

The question that we have is the intent of rulemaking covering turn signal lamps. The turn signal lamp, SA J588e, last revised September, 1970, includes Item 3.4 which states, "The flashing signal from a double-faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles."

With the baffling area reduced inside of the lamp as indicated by the sample, and since the requirements are very subjective, we need an opinion as to whether the lamp does or does not meet the intent of Federal Motor Vehicle Safety Standard 108.

Would you please review the sample and give us your opinion as soon as possible.

Yours very truly,

THE GROTE MANUFACTURING COMPANY

C. J. Newman Vise President, Engineering

CJN/aj

ID: nht76-5.43

DATE: 03/19/76

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: F. A. McNiel

TITLE: FMVSS INTERPRETATION

TEXT: On February 12, 1976, this agency denied your petition to amend S4.5.4 of Motor Vehicle Safety Standard No. 108 to read:

"The stoplamps on each vehicle shall be activated upon application of the service brakes, or by other beneficial means which will not impair the lighting system or the mechanical functioning of the vehicle."

You have now re-petitioned us on February 16, 1976, to amend S4.5.4 to read:

"The stoplamps on each vehicle shall be activated upon application of the service brakes. This action may be supplemented by other beneficial means which will improve the performance of the stoplamps without impairing the lighting system or the mechanical functioning of the vehicle."

This petition is unnecessary, because as you have now worded your suggested amendment it essentially reflects the present requirements of the standard. We do not view S4.5.4 as prohibiting a means of stoplamp activation supplemental to activation by application of the service brakes.

Any supplemental lighting device, however, is subject to the general prohibition of S4.1.3 against installation of motor vehicle equipment that impairs the effectiveness of lighting equipment required by Standard No. 108. For example, a positioning device that activates the stoplamps whenever the accelerator pedal is released would impair the effectiveness of the stoplamps by providing an ambiguous signal, as release of the accelerator does not always signify that the vehicle operator intends to brake.

You also questioned whether NHTSA desires to see improvements in motor vehicle stoplamp systems. Docket No. 74-5 represented a tenative effort to provide better systems on an optional basis, but on the basis of comments to the docket and our research contracts, we are re-evaluating the entire subject. Your denial must also be considered in this context, and at the present time radical changes in rear lighting are simply premature.

The remainder of your letter was also of interest. Dr. Haddon remarked that performance standards afford the private sector optimum flexibility in designing to meet the Federal standards. His comment reflected a statutory mandate which this agency continues to adhere to in its rulemaking actions. However, as I wrote you on February 12, any performance standard is design restrictive to some extent, with the restrictions ideally only as narrow as reasonably necessary to achieve the desired safety performance. In some areas (e.g. the occupant protection provisions for vehicle interiors in impacts, Standard No. 201) a great deal of design freedom is afforded, while others (e.g. the headlighting requirements of Standard No. 108) may be quite restrictive because safety-related factors such as availability of replacements, uniformity of color and location, and detection of function are more important than design freedom.

Sincerely,

ATTACH.

F. A. McNeil 611 Bouldin Avenue Austin, Texas 78704

FEBRUARY 16, 1976

U. S. Department of Transportation National Highway Traffic Safety Administration

Appeal of Petition Denial - Re: N40-30

Gentlemen:

In reply to your letter of February 12, 1976 wherein you deny my petition for the correction of subsection S4.5.4 and S4.6 (b) as set forth by the existing Federal Motor Vehicle Safety Standard No. 108, I offer the following comments.

In relation to S4.5.4, I agree with your statement that a signal to other drivers that the service brakes are being applied is precisely the performance being sought in S4.5.4. The possibility of an improvement over this 'one shot' stoplamp warning system is what I am endeavoring to get incorporated into Federal Motor Vehicle Safety Standard No. 108, subsection S4.5.4.

As for subsection S4.6 (b) I agree that from the standpoint of traffic safety there is no need for the amendment that I have proposed. My proposal was based primarily on economy. If for any conceivable reason the flashing of the headlamps and the side marker lamps for signaling purposes could enhance traffic safety, cutting a flasher unit directly into the existing lighting circuit would be much less costly than the installation of the additional wiring and switching means that would be required to isolate the headlamps and the side marker lamps from the conventional lighting circuit.

My suggested amendment to S4.5.4 stated - "The stoplamps on each vehicle shall be activated upon application of the service brakes, or by other beneficial means which will not impair the lighting system or the mechanical functioning of the vehicle." - I regret that my choice of wording could be construed to indicate any intent that activation of the stoplamps upon application of the service brakes could be deleted under any circumstances. Such an act would very definitely impair the vehicle's lighting system, and so would therefore be unacceptable under such revised standard. - However, to make my proposal crystal clear, I am rephrasing my petition to amend FMVSS No. 108, subsection S4.5.4 to read as follows --

"The stoplamps on each vehicle shall be activated upon application of the service brakes. This action may be supplemented by other beneficial means which will improve the performance of the stoplamps without impairing the lighting system or the mechanical functioning of the vehicle."

Such an amendment would provide a standard against which any means that would improve the performance of a vehicle's stoplamp warning system could be tested -- such as a means to signal other drivers that the brakes are going to be applied (prior to the time of the actual application of the brakes) in the event that a 'panic' or other sudden stop is going to be made.

The reason cited for denying my petition for amendment of S4.5.4 was - "Since the requirement is limited to the desired safety performance, we find it valid" - Does this statement mean - as it implies - that the NHTSA has no desire to see any improvement in a motor vehicle's antiquated stop warning system? - I find this to be extremely odd in view of the fact that your department previously informed me that "rear end collisions account for 10 per cent of the fatal motor vehicle accidents and 49 per cent of all motor motor vehicle accidents". - As for validity, the reasons for your denial of my petition are certainly not valid in relation to the statements made by Director Haddon December 14, 1967.

Again, I strongly urge that the National Highway Traffic Safety Administration approve my revised petition for the amendment of Federal Motor Vehicle Safety Standard No.108, subsection S4.5.4 as set forth above.

Respectfully,

Fred A. McNiel Traffic Safety Advocate

copy: Hon. J. J. Pickle

ID: cavallo.ztv

Mr. Jason J. Cavallo
Halcore Group, Inc.
3800 McDowell Road
Grove City, Ohio 43123

Dear Mr. Cavallo:

This is in reply to your e-mail of June 18, 2003, and your letter of June 20, to Taylor Vinson of this Office, asking for an interpretation of certain provisions of the Early Warning Reporting (EWR) regulation, found in 49 CFR Part 579.

You reported in your e-mail that Horton Emergency Vehicles (Horton) is a subsidiary of Halcore Group which also "owns two other emergency vehicle manufacturers," and that you have been told that "we need to combine our overall production between all three companies and report as a Group 1 manufacturer." This statement formed the basis of the first question in your letter of June 20:

"1. When making the determination between group 1 and group 2 reporting levels what is NHTSAs policy on production totals when a parent company owns multiple subsidiaries? Does the parent have to report as one on behalf of its subsidiaries? Or, can each subsidiary report individually?"

Halcore was formed in 1998 through the combination of Horton Emergency Vehicle Company (Horton), American Emergency Vehicles (AEV) and Leader Industries (Leader), each of which makes ambulances. Halcore is regarded as the largest ambulance manufacturing corporation in North America. (see, www.aev.com). Halcores website (www. Halcore.com) refers to Horton, AEV and Leader. AEV refers to itself as a division of the Halcore Group, Inc. In legal proceedings, Leader has referred to itself as Leader Industries, a Division of Halcore Group, Inc. Leader is the California distributor for Horton and AEV. (www.Leader.com). Under the EWR regulation, the definition of "manufacturer" at 49 CFR 579.4(c) includes parents, subsidiaries, and affiliates. For purposes of determining whether the production of vehicles meets or exceeds the 500 vehicles per year threshold in Section 579.21 et seq., the production of the divisions, parent, subsidiaries and affiliates must be aggregated. However, under section 579.3(b), the parent may report collectively or the incorporated entities may report separately, provided that all vehicles are covered by the reporting.

You related that Horton is a final stage manufacturer that does "not warrant the chassis," and that "if a user has a chassis problem we dont usually hear about it."Typically, if there is a problem with the chassis, the vehicles are taken to their "local chassis dealers for warranty and repair issues." You asked about Hortons EWR reporting responsibilities on chassis-related warranty matters, commenting that you believed "the chassis manufacturer would have to report the warranty claim" because Horton is not paying the claim. This issue formed the basis of the first part of your second question. Our reply is that, as to the narrow question posed, you are correct. Hortons responsibility is to report warranty claims that are submitted to it and that it pays.

As the second part of your second question, you also asked (as phrased in the e-mail) that "if an end user contacted us with a chassis issue and we advised them to contact their local chassis dealer does that constitute a reportable complaint?" The answer is yes; Horton would have to include this incident in its numerical count of consumer complaints if the substance was within the scope of matters covered by the definition of "consumer complaint" in Section 579.4. The term "consumer complaint" is a broad one; it covers "a communication of any kind made by a consumer (or other person) to or with a manufacturer . . . expressing dissatisfaction with a product, or relating the unsatisfactory performance of a product . . . ."

Your third question concerned reportable components on emergency vehicles. You related in your e-mail that you have been informed that "certain items on an emergency vehicle, specifically emergency lighting, interior lighting, and interior cabinetry, are not reportable items for TREAD purposes." However, it is your understanding that all items are reportable; i.e., "an exterior light was reportable as an exterior light regardless of whether it was an emergency light or headlamp." Your understanding is correct. The term for reporting that covers emergency lights and headlamps is "exterior lighting," defined in the EWR to mean "all the exterior lamps."

You have also asked in your e-mail "how would one categorize interior lighting and interior cabinetry? Would that be electrical and structure respectively?"You are correct in surmising that interior lighting is covered under the EWRs term "electrical system." That term is defined to mean "any electrical or electronic component of a motor vehicle that is not included in any one of the other reporting categories enumerated" in the EWR regulation. This includes interior lighting.Without having a description of the interior cabinetry that is the subject of your question, it would be considered "structure" only to the extent that it "serves to maintain the shape and size of the vehicle, including the frame, the floorpan, the body, bumpers doors, tailgate, hatchback, trunk lid, hood, and roof." Ordinarily, interior cabinetry does not serve that function. Interior cabinetry does not fall within any of the other defined components and system. Accordingly, it would be a component of a motor vehicle that is not covered by the EWR regulation. However, if an incident involving a death or injury results in Hortons receiving a claim, or a notice alleging or proving that the death or injury was caused by a possible defect in the interior cabinetry, or any other reportable information involving interior cabinetry, Horton would have to report that claim or notice and utilize Code 98 as the system or component involved.

Your letter asked, in its third question, "Is there a set of criteria that an item must meet in order to be reportable?" The EWR specifies certain defined components and systems for which information is required, and assigns them code numbers for reporting purposes. As indicated above, in compiling reportable information under the EWR regulation, a manufacturer must report under Code 98 for items of equipment not covered by the other Codes. Thus, all items of motor vehicle equipment are covered by a reporting Code, either under those pertaining to specified components or systems, or under Code 98 for those that are not covered by one of the other Codes.

If you have further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:579
d.7/21/03

ID: nht76-5.42

DATE: 06/02/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 8, 1976, asking for an amendment of S4.1.1.21 of Motor Vehicle Safety Standard No. 108 to allow a plus tolerance of 7.5 percent on maximum wattage requirements for Type 1A and 2A headlamps.

I enclose a copy of an interpretation furnished the General Electric Company which states that such a tolerance is allowed. However, to clarify our intent we plan to amend Standard No. 108 in the near future in the manner that you suggest.

ID: aiam0099

Dear Mr. Nine: Thank you for your letter of August 9, 1968, containing literature o 'Super-Lite' which will be an optional lighting device on the 1969 Dodge Polara and Monaco Models.; According to the literature, 'Super-Lite' is an auxiliary o supplemental light to be used in conjunction with the low beams of the regular headlamps.; For many years, all lighting devices used on motor vehicles registere in New Jersey have been required to be approved by the New Jersey Division of Motor Vehicles. Lighting devices are added to our approved list after a sample has been submitted along with a report from an independent testing laboratory showing that the device meets the standards of the Society of Automotive Engineers. We will also add a motor vehicle lighting device to our approved list after we receive an Approval Certificate from the American Association of Motor Vehicle Administrators showing that the device meets the SAE Standards.; Electric Supplementary Lamps, such as the 'Super- Lite' are covered b SAE Standard No. J582. Perhaps you have submitted a sample light and the necessary test report to the AAMVA, but as yet, we have not received a copy of the Approval Certificate.; In case you desire to have us approve the 'Super- Lite' on the basis o New Jersey alone, please send us a sample and test report, as mentioned above.; Unless the 'Super-Lite' is on our approved list at the time moto vehicles equipped with the lighting device are going through our inspection stations, the vehicles will have to be rejected.; New Jersey R.S. 39:3-51 concerns the mounting and aiming of auxiliar driving lights. A copy of this section is enclosed for your information.; Very truly yours, John A. McLaine, Chief, Automotive Engineerin Standards;

ID: nht89-2.39

TYPE: INTERPRETATION-NHTSA

DATE: 07/21/89

FROM: RICHARD L. VAN IDERSTINE -- SAFETY STANDARDS ENGINEER, NHTSA

TO: DOCKET SECTION; THRU: RALPH HITCHCOCK, DIRECTOR -- OFFICE OF VEHICLE SAFETY STANDARDS; VIA: OFFICE OF CHIEF COUNSEL

TITLE: ACTION: SUBMISSION TO DOCKET 85-13, NOTICE 7 AND NOTICE 8, OF A CONGRESSIONAL INQUIRY AND NHTSA'S RESPONSE CONCERNING ULTRAVIOLET EMISSIONS FROM HEADLAMPS

ATTACHMT: ATTACHED TO LETTER DATED 3-15-90 TO T. CHIKADA, STANLEY ELECTRIC CO., LTD., FROM STEPHEN P. WOOD, NHTSA; [A35; STD. 108]; ALSO ATTACHED LETTER DATED 8-9-89 TO ERIKA Z. JONES, NHTSA, FROM T. CHIKADA, STANLEY ELECTRIC CO., LTD.; [OCC 3832]

TEXT: Please place the attached letters in Docket 85-15; Notice 7 and Notice 8, for Standard No. 108. The attachments concern the potential for ultraviolet light emissions from future headlighting systems such as those using a high intensity discharge, gaseou s discharge, or short arc metal-halide light sources.

Attachment (w/10 copies)

ID: nht93-9.4

DATE: December 6, 1993

FROM: Tilman Spingler -- Automotive Equipment Div. 2, Robert Bosch GmbH

TO: Chief Counsel -- NHTSA

TITLE: Petition for an "Exemption for Inconsequential Noncompliance" to FMVSS 108, S7.8.5.2 (On Vehicle Aiming)

ATTACHMT: Attached to letter dated 1/26/94 from John Womack to Tilman Spingler (A42; Std. 108; Part 573)

TEXT:

FMVSS 108 requires in the above mentioned paragraph a graduation of not larger than 0.19 degree for the scale of the vertical and 0.38 degree for the scale of the horizontal aim indicator. To make the scales more clearly legible and to avoid confusions we kindly ask for the permission to use scales with graduations of 0.2/0.4 degree.

We principally prefer scales with numbers indicating the graduation.

It is our opinion that there is no influence on the accuracy of aim because 1/100 degree is less than the width of the graduation-lines on bubble vials and scales used on headlamps.

ID: aiam3550

Dear Mr. Pachuta: This is in reply to your letter of March 8, 1982, asking the curren status of three-wheeled motor vehicles under the Federal Motor Vehicle Safety Standards.; As you know from my letter of November 24, 1976, to HM Vehicles, a cop of which you enclosed, three-wheeled motor vehicles are classified as 'motorcycles' under the standards. Obviously the configuration of a three-wheeled enclosed vehicle differs greatly from that of the two-wheeled machine that comes to mind when the word 'motorcycle' is mentioned. As my 1976 letter indicates, the agency was seeking a more realistic regulatory scheme for three- wheeled vehicles, for obviously our motorcycle standards were written with two-wheeled vehicles in mind. But because three- wheeled vehicles did not comprise a significant part of the market, the agency decided that its priorities in motor vehicle safety lay elsewhere, no change in the definition of 'motorcycle' was ever adopted, and it still encompasses three-wheeled vehicles.; You have also asked whether a three-wheeled vehicle can be registere and inspected as a passenger car. Under the preemption provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)), Pennsylvania is bound to treat three-wheeled vehicles as 'motorcycles' in those areas that are covered by Federal safety standards that apply to motorcycles. Further, it may apply its own motorcycle standards in areas not covered by Federal standards. This means, for example, that Pennsylvania could not require a three-wheeled vehicle to have two headlamps since one is adequate under our Safety Standard 108. On the other hand, Pennsylvania could require a backup lamp device since Standard No. 108 contains no such requirement for motorcycles. Thus, it would seem that Pennsylvania should register and inspect these vehicles as motorcycles to the extent possible.; PAGE 2 WAS INADVERTENTLY MISSING FROM ORIGINAL

ID: aiam4872

Dear Mr. Kirchgraber: This is in reply to your letter of April 16 1991, with respect to which Federal motor vehicle safety standards, if any, must be met in order to sell an exterior tire/wheel cover with reflective characteristics that will help to make 'the vehicle more visible to the surrounding traffic.' In addition, you 'want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard', and ask for the citation to 'appropriate federal test standards from the code of federal regulations for similar automotive accessories.' There are no Federal motor vehicle safety standards that establish performance requirements for reflective material of this nature, or for wheel coverings on exterior-mounted tires. The standard on vehicle lighting, Motor Vehicle Safety Standard No. 108, does prohibit, as original equipment, the installation of a 'reflective device or other motor vehicle equipment' that impairs the effectiveness of lighting equipment required by the standard. It is theoretically possible that your material could create glare in the eyes of a following operator so that (s)he would fail to respond to a stop signal, or a turn signal. The samples submitted with your letter are too small for us to judge its reflectivity, and we suggest that you conduct your own tests, approaching a vehicle with the tire cover from the rear, with headlamps on the lower beam. This, to us, is preferable to your redesigning the material to conform to any federal test standard relating to reflectivity. Although the color of lighting equipment on the rear is generally red, with amber permitted for turn signals, and white required for back up lamps, we do not believe that the use of additional colors would create any confusion. In short, we believe that the wheel cover will be perceived for the wheel cover it is. I hope that this responds to your concerns. Sincerely, Paul Jackson Rice Chief Counsel;