Interpretation ID: 2643o

Mr. Billy S. Peterson
President
Automotive Safety Testing, Inc.
Product Liability-Testing-Certification
at TRC of Ohio
East Liberty, OH 43319

Dear Mr. Peterson:

This is in reply to your letter of September 23, 1987, with respect to positioning of rear mounted lamps and reflectors in accordance with Federal Motor Vehicle Safety Standard No. l08. Your client has designed a vehicle in which the backup lamps and rear reflex reflectors would be mounted on the deck lid, and you have asked whether there are any current or contemplated prohibitions that would preclude this design.

The lamps in question will be mounted on a rigid part of the vehicle as required by paragraph S4.3.1 of Standard No. l08, and the deck lid will be closed and the lamps and reflectors in full view under normal operating conditions. The visibility requirements of lamps and reflectors in Standard No. l08 are predicated on the normal driving or closed deck lid position. Since the use of motor vehicles, including driving with deck lids open or otherwise having the lamps and reflectors obscured by a particular load on the vehicle is under the jurisdiction of the individual States, we do not anticipate rulemaking on this subject. Thus this design is not prohibited by Standard No. l08.

Sincerely,

Erika Z. Jones Chief Counsel ref:l08 d:1/28/88