Interpretation ID: nht92-3.8

DATE: 10/24/92

FROM: GEORGE D. JAMES, JR. -- SAFETY CHAIRMAN, UNIT 169 WBCCI

TO: PAUL JACKSON RICE -- CHIEF COUNSEL D.O.T.

TITLE: TEKONSHA COMMANDER & VOYAGER ELECTRONIC BRAKE CONTROL ("CONTROL")

ATTACHMT: ATTACHED TO LETTER DATED 12-4-92 FROM STEPHEN P. WOOD TO GEORGE D. JAMES, JR. (A40; STD. 108)

TEXT: I respectfully suggest that you have been hornswoggled by TEKONSHA into approving their electronic brake controllers for trailers.

You say that "IT IS THEORETICALLY POSSIBLE THAT THE CONTROL WILL NEVER BE OPERATED DURING THE LIFE OF THE TOWING VEHICLE."

Mr. Rice, that is WRONG!

Any Travel Trailer tow car driver who has any experience uses brake "controller only" WHENEVER he tows a trailer.

First, he uses the CONTROLLER ONLY to check his trailer brakes to be sure they ARE OPERATING. If this is done on the highway, the trailer stop lights should come on for his safety and safety of any following vehicle.

Second, he uses the CONTROLLER ONLY any time the trailer is PUSHING THE TOW CAR (down hills, approaching intersections, and especially when conditions are less than perfect (rain, snow, ice, gravel and sand) to keep the trailer from trying to pass the tow car.

The trailer stop lites should come on in such a situation.

Third, using CONTROLLER ONLY is an effective way to recover from a "sway situation" and when this is done the trailer stop lites should come on.

An experienced trailer tower also knows that under no circumstances should he lock the wheels of the trailer with his brakes. To safely operate a brake system on a tow car/trailer combination one must PRACTICE. Frequent practice prepares the operator for safe action when the need arises.

And trailer stop lights should go on even when practicing.

A sensitive, PRACTICED hand on a good controller is the only route to safe driving. User reports indicate that these Tekonsha controllers are an excellent device in all respects EXCEPT that the TRAILER STOP LITES are not activated whenever the CONTROLLER ONLY is used.

AND THIS IS NOT SAFE OPERATION.

I have over 200,000 miles on my present Airsteam Travel Trailer - without any accidents, thank the Lord (and my brake controller.) I use my CONTROLLER ONLY every time we go on the highway - and MY trailer stop lites work every time. I would not go on the highways if it didn't.

Mr. Rice, I think your people should review your thinking and rewrite the specs on this matter. And I think that TEKONSHA should redesign their controllers AND recall those that have been delivered to dealers or installed on tow cars.