Mr. David M. Wise
Gary Precision Products
530 Old Post Road No. 3
Greenwich
CT 06830;

Dear Mr. Wise: This is in reply to your letter of August 7, 1986, asking if Federa Motor Vehicle Safety Standard No. 108, or any other Federal regulation applies to a plastic ice scraper with a reflector on it that you may manufacture.; Although the title of Standard No. 108 is *Lamps, Reflective Devices and Associated Equipment*, the reflective devices covered by the standard are those that are mounted on the rear and side of a motor vehicle, which are necessary for signalling and the safe operation of vehicles during darkness and other times of reduced visibility. It does not apply to ice scrapers. Nor does the other Federal motor vehicle safety standard dealing with reflectivity, Standard No. 125 'Warning Devices,' or any other regulation of this Department.; I hope this answers your question. Sincerely, Erika Z. Jones, Chief Counsel