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Interpretation ID: nht88-1.88

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 7, 1988 EST

FROM: MAX J. MIZEJEWSKI -- EXECUTIVE DIRECTOR, FOREIGN MARKETING SPECIALISTS, INC.

TO: OFFICE OF THE CHIEF COUNSEL, NHTSA

TITLE: ROADREADER

ATTACHMT: LETTER DATED 11-03-88 TO M. J. MIZEJEWSKI; FOREIGN MARKETING SPECIALISTS, INC., FROM E.Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: The purpose of this letter is to receive written confirmation that the interpretation of the rules and regulations covering the product described below is accurate. Our company is importing a device manufacturered in France that attaches to but is not a n integral part of automobiles and trucks. In reading the regulations it seems as if we fall outside of any specific legal requirement to obtain certification.

The device which we call Roadreader is designed to have two sensors mounted on the front of the automobile which are then tied into an on-board computer which is further wired into the left and right turn light wiring. The device is designed to give a v isual and audible alarm at the time that a vehicle would start to drift off of the highway, crossing either the yellow lane on the left or the white line on the right. It in no way is attached to or affects either the acceleration or braking and does no t in any way interfere with line of sight vision or vehicle lighting. The wiring to the turn indicators is only to allow the device to be shunted upon the turn indicator being put on in order to allow lane changes without the alarm going off.

I am aware that as an importer we assume the responsibilities of the manufacturer for such things as any product recall that might become necessary for some unforeseen reason.

The device is available for your inspection and we'd be most happy to forward it to any governmental agency that would require it, as well as to conform to any other request or requirements of yours or any other agency that we should check with.

I look forward to hearing from you and thank you in advance for your prompt response to this request.