Interpretation ID: nht94-4.84

TYPE: INTERPRETATION-NHTSA

DATE: November 16, 1994

FROM: Yoshiaki Matsui -- Manager, Legal & Homologation Sect., Stanley Electric Co., Ltd.

TO: Patrick Boyd -- Office of Rulemaking, NHTSA

TITLE: Re: 7% haze requirement for reflectors (Docket No. 93-15; Notice 2)

ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO YOSHIAKI MATSUI (A42; REDBOOK 2; STD. 108)

TEXT: We have a question about the applicability of the above requirement for reflex reflector materials.

According to the Final Rule issued by the Federal Register of November 2, the amended haze requirement shall be effective on November 1, 1995. Our question is that if this requirement shall be applicable to replacement reflex reflectors or not.

For replacement reflex reflectors, two possible cases are in problem. Would you please inform us if the amended haze requirement shall be applicable in each case.

First case - Replacement reflex reflectors manufactured after the effective date, but the vehicle to which the reflex reflectors are fitted is no longer manufactured after the effective date.

Second case - Replacement reflex reflectors manufactured before the effective date, which may be fitted to a vehicle manufactured before or after the effective date. (In this case, the same type of vehicles are manufactured before and after the effectiv e date continuously.)

Your prompt reply will be highly appreciated.