Interpretation ID: nht90-3.54

TYPE: INTERPRETATION-NHTSA

DATE: August 13, 1990

FROM: Thomas J. Loughran -- V.P. Engineering, The Grote Manufacturing Company

TO: General Jerry Ralph Curry -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-10-90 from P.J. Rice to T.J. Loughran (A36; Std. 108)

TEXT:

On December 13, 1989 the Bargman Company requested an opinion regarding a turn signal lamp with a combined reflector. Acting Chief Counsel Stephen P. Wood issued an opinion on February 26, 1990. The opinion used the terms tail lamp and turn signal lamp interchangeably. The result is chaos, as you can see from the attached copy of a release published in an industry magazine.

Although I totally disagree with his opinion regarding he suitability of an amber reflector as an auxiliary device on the rear of a vehicle, it is not as disastrous as promulgating the idea that an amber tail lamp is also acceptable. I do not believe th e amber tail lamp was his intent but that has been the effect as a result of a inadvertent use of words.

Both of these conditions are a major disappointment to those who take highway safety seriously, first, because of the impairment of highway safety, and second, because the opinion was issued without benefit of review and comment by concerned individuals and organizations.

Your review of this condition will be appreciated. (Attached is an article entitled, It's the Law, Rear Amber Reflector, text omitted.)