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Senior Trooper W. L. Hill
Texas Department of Public Safety
Highway Patrol
2720 Industrial Boulevard
Abilene, TX 79606
Dear Trooper Hill:
This is in reply to your request to Taylor Vinson of this Office for
our opinion on the following two questions regarding compliance with
Federal Motor Vehicle Safety Standard No. 108, Lamps,
Reflective Devices, and Associated Equipment. You are requesting
this information in connection with a court case in which a driver was
cited for operating a vehicle equipped with a replacement taillamp
consisting of a clear lens and a red bulb. You mentioned the driver's
opinion that Mercedes-Benz was offering such a lamp.
Your first question is whether, to the best of our knowledge, a motor
vehicle taillamp is being manufactured, either as original or
replacement equipment, which includes a red bulb and a clear lens, and
which is certified as complying with Standard No. 108. Our
answer is that, to the best of our knowledge, it is not economically
feasible under the current state of the art to manufacture a taillamp
with a red bulb and a clear lens that complies with Standard No. 108's
taillamp requirements, and we are not aware of any such product.
Your second question is whether red reflective tape that is affixed
to a vehicle after a protective backing is removed can be a rear reflex
reflector replacement under Standard No. 108. The tape has no DOT
marking. The answer is no; the
original rear reflex reflector, whether incorporated in the lamp or
separately mounted on the body, would have been made of plastic in order
to comply with SAE Standard J594f, Reflex
Reflectors, incorporated by reference in Standard No. 108 as the
requirement for reflex reflectors. A replacement rear reflex
reflector would also need to be made of plastic to meet these
requirements.
If you have any further questions, you may call Taylor Vinson at
202-366-5263.
Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.10/5/00
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