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Interpretation ID: aiam3380

Mr. Eric C. Oppenheim, Esq., Corporate Attorney, Kux Manufacturing Company, 12675 Burt Road, Detroit, MI =48223; Mr. Eric C. Oppenheim
Esq.
Corporate Attorney
Kux Manufacturing Company
12675 Burt Road
Detroit
MI =48223;

Dear Mr. Oppenheim: This is in reply to your letter of November 23, 1980 asking whether an Federal regulation 'prohibits the use of reflective red markings on the front of vehicles.'; The Federal Motor Carrier Safety Regulation administered by the Federa Highway Administration of the Department of Transportation impliedly prohibit the use of red reflectors on the front of vehicles subject to its jurisdiction by requiring that all reflectors, other than those at the rear, be amber in color (49 CFR 393.26(d)). The common contract, private or exempt carriers covered by this requirement are found in 49 U.S.C. 303.; The Federal motor vehicle safety standard on vehicle lighting (49 CF 571.108) applicable to the manufacture of all motor vehicles contains a general prohibition (paragraph S4.1.3) against installation of reflective devices that impair the effectiveness of required lighting equipment. Because of the generally accepted lighting coding of amber to the front and red to the rear, we would view installation of red reflective material on the front of a vehicle as prohibited by S4.1.3.; Sincerely, Frank Berndt, Chief Counsel