Interpretation ID: nht90-4.52

TYPE: Interpretation-NHTSA

DATE: November 1, 1990

FROM: Mitch L. Williams -- President, Hella Inc.

TO: Richard Van Iderstine -- Office of Vehicle Safety Standards

TITLE: Re Proposed new product from Hella

ATTACHMT: Attached to letter dated 11-8-90 from Mitch L. Williams to Richard Van Iderstine; Also attached to letter dated 12-24-90 from Paul Jackson Rice to Mitch L. Williams (A37; FMVSS 108)

TEXT:

Hella is considering introducing a new product which could have certain safety implications. We are considering introducing a range of rear spoilers with integrated third rear brake lights. Obviously, for vehicles which are not equipped originally with third rear brake lights, this would upgrade them to current safety standards.

Our question is from a regulatory viewpoint, how would NHTSA view the addition of a rear spoiler with integrated third rear brake light to a vehicle already originally equipped with a third rear brake light? Could you be so kind as to give us an opinion on this matter?

Thank you for your assistance in this matter.