ID: nht89-3.53

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 11, 1989

FROM: JOE DABROWSKI -- VP ENGINEERING TMC/MCI, TRANSPORTATION MANUFACTURING CORP. TO: FRANK BERNDT -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO R. W. SCHREYER FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 3-5-90 TO HARRY THOMPSON FROM R. W. SCHREYER, LETTER DATED 3-22-89 TO KEITH A. MCDOWELL FROM ERIKA Z. JONES, AND LETTER DATED 3-25-77 TO ROBERT B. KURRE, WAYNE CORPORATION, FROM FRANK BERNDT. TEXT:

During the 1989 SAE Truck & Bus meeting held in Charlotte, N.C., I met with a Dale Guthrie, Engineering Manager for Thomas Built Buses. During the course of our meeting, our conversation turned to seat belts and he advised me of a letter (copy attached) he received from you responding to his inquiry as to an interpretation of the requirements of Standard 210, Seat Belt Assembly Anchorages.

In particular, my inquiry addresses how much force must be used when testing seat belt anchorages in Intercity coaches to certify compliance with the standard and whether it is necessary to test simultaneously all seat belt assemblies as called out in St andard No. 207, Seating Systems.

If we can use the same interpretation that the referenced letter addresses, we would be able to comply with some of the requests we are receiving for seat belts in intercity buses.

Your attention to this matter and prompt reply are appreciated.

ID: nht89-3.54

TYPE: INTERPRETATION-NHTSA

DATE: 12/13/89

FROM: JIM EVANS -- QUALITY CONTROL DEPT., THE BARGMAN COMPANY

TO: STEVEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 02-26-90 TO JIM EVANS, THE BARGMAN CO., FROM STEPHEN P. WOOD, NHTSA; (REDBOOK) A35; VSA 103(D); STD. 108

TEXT: My company manufactures lighting products for the recreational vehicle industry and we are in need of an interpretation of the rules in FMVSS 108 concerning the use of reflex reflectors on the rear of vehicles. I can find in this standard where two (2) red reflex reflectors are required on the rear of a vehicle (Tables I, II, III, IV) but I cannot find anything in the standard that would prohibit the use of any other color reflectors that could be used in addition to the red reflectors.

Specifically, we manufacture a red taillight lens that has a reflex reflector area around the outer edge of the lens. The stop, turn and tail, as well as the reflex functions all exceed the minimum requirements for these functions.

One of our customers has asked us to mold this same lens in yellow so that it could be used for the turn signal function. It would be mounted side by side with the red unit which would now be used for only stop and tail functions. The problem now arise s where both the yellow and red lens would be visable to traffic approaching from the rear. I checked with a local State Police Post here in Michigan, and they were able to find a section in the State Code that clearly states that reflectors mounted on the rear of a vehicle shall reflect a red color (I am enclosing a copy of this section for your reference). As I stated in my opening paragraph, I cannot find an equivalent ruling in the National standard. I am hoping that your office may have already addressed this problem in the past and that a ruling is already in effect.

My questions are two-fold: First, is it legal to put any other color reflector on the rear of a vehicle as long as the red reflectors are also present? Secondly, if in fact this situation is illegal (which I believe it probably is), could the National st andard be amended to show this fact and eliminate future confusion? Whichever way is correct, I would like to request a written statement to that effect as well as any supporting documentation for the ruling.

I am looking forward to hearing from you as soon as possible so that we can clear this matter up once and for all. Thank you.

Enclosure

(d) On every trailer or semitrailer having a gross weight in excess of 3,000 pounds:

On the front, 2 clearance lamps, 1 at each side.

On each side, 2 side marker lamps, 1 at or near the front and 1 at or near the rear.

On each side, 2 reflectors, 1 at or near the front and 1 at or near the rear.

On the rear, 2 clearance lamps, 1 at each side, also 2 reflectos, 1 at each side, and 1 stop light.

(e) On every poletrailer:

On each side, 1 side marker lamp and 1 clearance lamp which may be in combination, to show to the front, side or rear.

On the rear of the poletrailer or load, 2 reflectors, 1 on each side.

(f) On every trailer or semitrailer weighing 3,000 pounds gross or less:

On the rear, 2 reflectors, 1 on each side if any trailer or semitrailer is so loaded or is of such dimensions as to obscure the stop light on the towing vehicle, then such vehicle shall (Illegible Words) with 1 stop light

(g) When operated on the highway, every vehicle which has a maximum potential speed of 25 miles an hour implement of husbandry, farm tractor or special mobile equipment shall be identified with a reflective device as follows:

An equilateral triangle in shape, at least 16 inches wide at the base and at least 14 inches in height, with a dark red border, at least 1 3/4 inches wide of highly reflective beaded material;

A center triangle, at least 12 1/4 inches on each side of yellow orange fluorescent materials.

The device shall be mounted on the rear of the vehicle, broad base down, not less than 3 feet not more than 5 feet above the ground and as near the center of the vehicle as possible. The use of this reflective device is restricted to use on slow movi ng vehicles specified in this section, and use of such reflective device on any other type of vehicle or stationary object on the highway is prohibited.

On the rear, at each side, red reflectors or reflectorized material visible from all distances within 500 to 50 feet to the rear when directly in front of lawful upper beams of headlamps.

Am. 1988, Act 383.

CI 257.689 Clearance and marker lamps and reflectors; color. [MSA 9.2389]

Sec. 689. (a) Front clearance lamps and those marker lamps and reflectors mounted on the front or on the side near the front of a vehicle shall display or reflect an amber color.

(b) Rear clearance lamps and those marker lamps and reflectors mounted on the rear or on the sides near the rear of a vehicle shall display or reflect a red color.

(c) All lighting devices and reflectors mounted on the rear of any vehicle shall display or reflect a red color, except the stop light or other signal device, which may be red or amber, and except that the light illuminating the license plate-shall be white.

CI 257.690 Same; mounting [MSA 9.2390]

Sec. 690. (1) Reflectors shall be mounted at a height not less than 15 inches and not higher than 60 inches above the ground on which the vehicle stands, except that if the highest part of the permanent structure of the vehicle is less than 15 inches , the reflector at such point shall be mounted as high as that part of the permanent structure will permit.

(2) The rear reflectors on a pole-trailer may be mounted on each side of the bolster or load.

(3) Any required red reflector on the rear of a vehicle may be incorporated with the tail lamp, but such reflector shall meet all the other reflector requirements of this chapter.

(4) Clearance lamps shall be mounted on the permanent structure of the vehicle in such a manner as to indicate its extreme width and as near the top thereof as practicable. Clearance lamps and side marker lamps may be mounted in combination if illumi nation is given as required herein with reference to both.

Am. 1988, Act 383.

CI 257.691 Same; visibility. [MSA 9.2391]

Sec. 691. (a) Every reflector upon any vehicle referred to in section 689 of this chapter shall be of such size and characteristics and so maintained as to be readily visible at nighttime from all distances within 500 to 50 feet from the vehicle when directly in front of lawful upper beams of headlamps. Reflectors required to be mounted on the sides of the vehicle shall reflect the required color of light to the sides, and those mounted on the rear shall reflect a red color to the rear.

(b) Front and rear clearance lamps shall be capable of being seen and distinguished under normal atmospheric conditions at the times lights are required at a distance of 500 feet from the front and rear, respectively, of the vehicle.

(c) Side marker lamps shall be capable of being seen and distinguished under normal atmospheric conditions at the times lights are required at a distance of 500 feet from the side of the vehicle on which mounted.

CI 257.692 Combination vehicles obstructed lights. [MSA 9.2392]

Sec. 692. Whenever motor and other vehicles are operated in combination during the time that lights are required, any lamp (except tail lamps) need not be lighted which, by reason of its location on a vehicle of the combination, would be obscured by another vehicle of the combination, but this shall not affect the requirement that lighted clearance lamps be displayed on the front of the foremost vehicle required to have clearance lamps, nor that all lights required on the rear of the rearmost vehicl e of any combination shall be lighted.

ID: nht89-3.55

TYPE: Interpretation-NHTSA

DATE: December 15, 1989

FROM: R.R. Chestnut -- Supervisor, Modified Vehicle Engineering Dept, Ford Motor Company

TITLE: Re Splicing Into The Stop Lamp Electrical Circuit

ATTACHMT: Attached to memo dated 6-6-90 from Tekonsha Engineering Company; Also attached to letter dated 8-31-78 from J.J. Levin, Jr. to L.F. Henneberger; Also attached to letter dated 5-2-84 from F. Berndt to L.F. Henneberger; Also attached to letter da ted 11-30-81 from F. Berndt to K.G. Moyer (A23; Redbook 3; Std. 108); Also attached to letter dated 9-10-90 from P.J. Rice to L.F. Henneberger (A36; VSA Sec. 103 (d); Std. 108); Also attached to letter dated 6-22-90 from L.F. Henneberger to P.J. Rice (OC C 4927)

TEXT:

Splicing Into The Stop Lamp Electrical Circuit

This bulletin emphasizes the importance of QVM Bulletin #8, issued October 13, 1989, which cautions builders concerning altering of connecting to stop lamp circuits. The stop lamp switch and related wiring not only control the stop lamps, but also provi de the brake on/off input to the electronic modules of the EEC, EAOD, speed control, and anti-lock brake systems. Splicing into a location that interrupts the signals to these modules can interfere with their proper functioning, including:

1. Affecting EFI engine idle speed quality 2. Preventing the EAOD torque converter clutch from applying at throttle openings less than half throttle 3. Deactivating anti-lock brake system operation 4. Preventing the speed control from disengaging upon braking

Attachments I, II, and III of this bulletin illustrate acceptable locations to splice into the stop lamp circuits of Econoline and F-Series vehicles.

Note that when stop lamps are installed in addition to the OEM stop lamps, the additional load must not exceed 6 amps (3 bulbs), yielding a total circuit draw not exceeding 10.4 amps (5 bulbs). Loads exceeding 10.4 amps can damage the stop lamp and/or t urn signal switch.

If you have any questions regarding this issue, please call the Body Builders Advisory Service Hotline on 1-800-635-5560.

ID: nht89-3.6

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 29, 1989

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: DAVID G. GOULD -- LEGISLATION DEPT., LOTUS ENGINEERING, NORFOLK, ENGLAND

TITLE: N

ATTACHMT: LETTER DATED JULY 5, 1989 TO STEVE WOOD, NHTSA, FROM DAVID G. GOULD, LOTUS ENGINEERING

TEXT: Thank you for your letter asking whether a world manufacturer identifier (WMI) assigned ny the Society of Automotive Engineers (SAE) pursuant to a contract with this agency may be deleted from SAE's register of assigned WMIs upon request of a foreign nat ional governmental agency, but without the consent of the holder of the WMI. Absent some extraordinary circumstances, the answer to your question is no.

49 CFR Part 565, Vehicle Identification Number - Content Requirements, sets forth format and content requirements for vehicle identification numbers (VINs). Section 565.4(a) specifies that the first three characters of the VIN shall be the manufacturer' s WMI, which is "assigned in accordance with Section 565.5(c) of this part." Section 565.5(c) specifies that the SAE assigns WMIs to vehicle manufacturers under contract with the National Highway Traffic Safety Administration (NHTSA).

No provision in NHTSA's regulations sets forth any procedures for deleting assigned WMIs from the SAE register upon the request of any party, even the manufacturer assigned the WMI. Similarly, no provision in the contract specifically addresses the issu e of deleting assigned WMIs for any reason. In its contract with NHTSA, SAE has agreed to "furnish the facilities, materials, personnel and services necessary to accomplish the work..."

We contacted the SAE's WMI Coordinator to learn how they have handled this situation in the past. We were informed that the WMIs are assigned by the SAE for an indefinite period with no express provision for revo- cation of the assignment. There have b een a few isolated instances in which the party to whom a WMI was assigned has contacted SAE and asked that the WMI assignment be revoked. In those instances, the SAE has granted the manufacturer's request but the revoked WMI is never reassigned to anot her manufacturer. To date, SAE has never been asked to delete an assigned WMI by any party other than the manufacturer to whom the WMI was assigned. If a situation arose in which the SAE was asked to delete an assigned WMI without the knowledge and con sent of the manufacturer to whom the WMI was assigned; the SAE assures us that they would not act on the request without consulting this agency.

If and when we are ever consulted by ShE for our opinion on how to handle such a request, we would carefully consider the circumstances of the particular case before advising SAE on how to respond to the request. As a general matter, however, NHTSA does not favor the deletion of assigned "WMIs for any reason.

Sincerely,

ID: nht89-3.7

TYPE: INTERPRETATION-NHTSA

DATE: 09/29/89

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TO: SHUICHI WATANABE -- MANAGER, AUTOMOTIVE LIGHTING HOMOLOGATION SECT. STANLEY ELECTRIC CO., LTD. JAPAN

TITLE: NONE

ATTACHMT: LETTER DATED 3/27/89 FROM SHUICHI WATANABE OF STANLEY ELECTRIC CO OF JAPAN TO ERIKA JONES OF NHTSA RE: MEASUREMENT OF INCIDENT LIGHT ANGLE

TEXT: Dear Mr. Watanabe:

This is in reply to your letter with respect to measurement of the incident light angle prescribed by Motor Vehicle Safety Standard No. 108 for license plate lamps. You have submitted six Figures for our consideration and reply. I regret the delay in r esponding.

Paragraph 6.5 (not 5.3.3) of SAE Standard J587 OCT81 License Plate Lamps (Rear Registration Plate Lamps) states:

"When a single lamp is used to illuminate the plate, the lamp and license plate holder shall bear such relation to each other that at no point on the plate will the incident light make an angle of less than 8 deg. to the plane of the plate, this angle be ing measured from the edge of the light emitting surface of the device farthest from the surface of the plate (see Fig. 3)."

With respect to your Figure A, you comment that, in order to determine the farthest point on the light emitting surface, "only the distance '1' between license plate and a plane runs parallel to it should be considered and not by distance 'm' nor 'n'".

In examining Figure 3 of SAE J587, you will note that the incident angle is measured by a line that extends from the edge of the light emitting surface of the lamp that is the farthest from the most distant point on the plate that the light can be expect ed to reach, to that point. With respect to your Figure A, the line "n" that extends from the edge of the lamp "p" to the bottom of the plate replicates the line shown in Figure 3, and thus is the correct one, not the perpendicular line "1".

Similarly, with respect to Figure B, a round license plate lamp, a line must be drawn from the bottom of the plate (such as line "n" in Figure A) to the farthest light emitting surface surface of the lamp (as shown in Figure 3, not your Figure B) in orde r to illustrate the farthest point.

With respect to Figures C and D, you have asked: "But if the farthest point can exist so may on a line or a plane . . . how could it be determined? Should it be for instance, left end, right end or center of them?" Figure C appears to depict an elongate d lamp in which "p"s are depicted at the left end, right end, and center. In this instance, "P2" is the edge of the light farthest from the surface of the plate, as represented by corner "Q". Though "Po" represents an edge of the lamp, at no place on t he plate is it the point "farthest from the surface of the plate". Thus, the measurement from "Q" to the tangent of the light emitting surface near "P2" is the line to be used to measure the 8 degree minimum angle.

Figure D appears also to represent an elongated lamp but one in which the lens area is directed more towards the plate. In this Figure, "P" is the edge of the lamp that is farthest from the plate. But because of the configuration of the lamp, light fro m this point is interrupted by a part other than a lens and cannot shine directly upon the plate. Your points "P1", "P0", and "P2" appear to indicate the points on the lamp surface where such interruption ceases and light shines directly upon the plate. Therefore, it is our opinion that in this instance "P2" is the edge of the lamp farthest from the plate, as represented by corner "Q".

You have also asked the same question with respect to Figures E and F. These Figures represent lamp designs with two light sources. However, in Figure E, the two light sources appear incorporated in a single lamp, and the requirements of paragraph 6.5 still apply. Thus, a line from Q, tangent to the light emitting surface of the lens near the point "P3" (and not your line "Q-"P3"), is the correct reference for angle measurement. Figure F, however, depicts the light sources as compartmentalized, and thus may be regarded as a two-lamp device. Paragraph 6.6 of SAE J587 establishes the requirement for two or more license plate lamps. It states:

"When two or more lamps are used to illuminate the plate, the minimum 8 deg incident light angle shall apply only to that portion of the plate which the particular lamp is designed to illuminate. The incident light angle shall be measured in the same wa y as provided in paragraph 6.5."

Under these circumstances the light emitting edge of the lamp farthest from the surface of the plate is the furthest edge of the lamp illuminating that portion of the plate, here represented by "P2". Thus, the angle to be measured would be determined wi th reference to a tangent line to the light emitting surface near "P2", from corner "Q".

I hope that this has answered your questions.

Sincerely,

ID: nht89-3.8

TYPE: INTERPRETATION-NHTSA

DATE: 10/04/89

FROM: DELL RANDLE

TO: GEORGE MILLER -- CONGRESS

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/1/89 FROM STEPHEN P. WOOD -- NHTSA TO U.S. CONGRESSMAN GEORGE MILLER; REDBOOK A34; STANDARD 125; LETTER DATED 10/17/89 FROM NANCY L. BRUCE -- D.O.T OFFICE OF CONGRESSIONAL AFFAIRS TO GEORGE MILLER, U.S. HOUSE OF REPR ESENTATIVES; LETTER DATED 10/12/89 FROM GEORGE MILLER, U.S. CONGRESSMAN TO NANCY BRUCE -- D.O.T OFFICE OF CONGRESSIONAL AFFAIRS; LETTER DATED 9/8/89 FROM ELIZABETH M LUCAS -- NATIONAL SAFETY COUNCIL, PRODUCT DEVELOPMENT TO DELL RANDLE OF SHIKARI CONSULTA NT FIRM LTD.

TEXT: Dear Congressman George Miller:

This letter is in regards to a safety device, which I designed, The Shi-Lite Holder, to eliminate the danger and the inconvience for stranded motorist. This eliminates motorist from leaving their car to place safety devices upon the freeway.

Description of Shi-Lite Holder:

* made of light wire, hooks on car window * after raising holder which is 17 inches above the roof of the car * two 3 inch red reflectors * two red high intensive light sticks * sit in a lantern container * Light sticks are non flammable * non toxic

On or about February 9, 1989, I was in contact with Assemblyman, Robert J. Campbell. He informed me that I should contact Captain Bob Hayworth of CHP, to evaluate the Shi-Lite, that it confirms with current Laws. Upon meeting with Captain Hayworth he i nformed me I would have to make a change on the product, change being no red could be seen from the front by oncoming traffic, this was corrected.

On or about April 12, 1989, I was in the office of Mr. Bernard Trenton, Commercial and Technical, Service Section, Sacramento, to get the final approval by his office. Mr. Trenton and his assistant, Mr. Kyle Larsen, evaluated and approved that the Shi-L ite holder meets all State requirement.

On or about May 18, 1989, a letter and picture was sent to National Safety Council, Chicago, IL. C/O Ms. Liz Lucas. In her letter dated September 8, 1989, they declined the product, reason being the Shi-Lite does not meet Federal Requirements as set by the Department of Transportation.

On or about September 21, 1989, I spoke with Dr. August and Mr. Harper in Washington, D.C. Dr. August mailed me D.O.T. Standard No. 125 Sec 571.125 on warning devices. I see nothing in the standard that relates to the Shi-Lite.

Since I see nothing in the regulations governing the Shi-Lite and its functioning and national rejected it on those basis, being a federal ruling, I would like for your office to look into this matter, since the rejection was based on Federal regulations .

Sincerely,

ID: nht89-3.9

TYPE: INTERPRETATION-NHTSA

DATE: 10/06/89

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TO: JOHN E. HAMMER -- JOHN E. HAMMER & ASSOCIATES

ATTACHMT: LETTER DATED 6/15/89 FROM JOHN HAMMER OF JOHN E. HAMMER AND ASSOCIATES TO KATHLEEN C. DEMETER; OCC 3626

TEXT: Dear Mr. Hammer:

This responds to your inquiry about the attachment of a rigid hood ornament onto a motor vehicle. You explained that you were developing an aftermarket kit to help prevent the theft of such hood ornaments. You asked about the legalities of an individua l owner using such a kit to attach a hood ornament. As explained below, while the agency does not regulate the actions of an individual vehicle owner, you as the manufacturer will have responsibilities under the National Traffic and Motor Vehicle Safety Act ("Vehicle Safety Act").

A replacement hood ornament kit would be considered "motor vehicle equipment" under section 102(4) of the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act). That section defines, in relevant part, the term "motor vehicle equipment" as:

any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle. . . .

The Safety Act gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Although NHTSA has issued motor vehicle safety standards for certain types of motor vehicle equipment, the re is no standard directly applicable to hood ornaments. Thus, the manufacture and sale of the aftermarket product to a vehicle owner for use with his or her vehicle would not be affected by the requirements of any Federal motor vehicle safety standard.

Although no standard directly applies to a hood ornament, there are several statutory provisions of which you should be aware. First, @ 108(a)(2)(A) of the Vehicle Safety Act states that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an appli cable Federal motor vehicle safety standard . . .

If using the hood ornament would adversely affect compliance with a safety standard, then a manufacturer, distributor, dealer, or repair business installing this product would "render inoperative" a design element in compliance with a Federal motor vehic le safety standard. The person who committed such an act would have violated @ 108(a)(2)(A), and would be subject to a civil penalty of up to $ 1000 for each @ 108 violation where a design element was "rendered inoperative." However, the provisions of 1 08(a)(2)(A) do not apply to the actions of a vehicle owner in adding or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Act by using the hood ornament kit even if doing so would adversely affect some safety feature in his or her vehicle or equipment.

Second, you will be a motor vehicle equipment manufacturer if you offer this product for sale. As a manufacturer, you will be subject to the requirements of @@ 151-159 of the Safety Act (15 U.S.C. 1411-1419), concerning the recall and remedy of products with defects related to motor vehicle safety. Section 102(11) of the Vehicle Safety Act defines "defect" as "any defect in performance, construction, components, or materials in motor vehicles or motor vehicle equipment." (emphasis added). Section 102 (1) defines "motor vehicle safety" as "the performance of motor vehicles or motor vehicle equipment in such a manner that the public is protected against unreasonable risk of accidents occurring as a result of design, construction or performance of motor vehicles . . ." (emphasis added).

If you or the agency determined that the product had a defect related to motor vehicle safety, you would have to notify all product purchasers of the defect, and either:

1. repair the product so that the defect is removed; or

2. replace the product with an identical or reasonably equivalent product that does not have the defect.

The manufacturer would have to bear the full expense of the notice-and-recall campaign, irrespective of the option chosen, for any owner who purchased the product less than eight years before the notice-and-recall campaign.

The agency does not determine the existence of safety-related defects, except in the context of a defect proceeding. I note that hood ornaments typically are constructed to yield to pressure so as to reduce the risk of injuries to pedestrians. Therefor e, it is possible that a rigid, non-yielding ornament might be considered a safety related defect if the rigid design were determined to pose an unreasonable safety risk.

I hope you find this information helpful.

Sincerely,

ID: nht90-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/90 Est.

FROM: MARK F. HOLMES

TO: STEPHEN P. WOOD -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/22/90 FROM STEPHEN P. WOOD -- NHTSA TO MARK F. HOLMES; REDBOOK A35; STANDARD 108

TEXT: Prior to your written reply to my letter dated October 31, 1989, concerning the Alarm Strobe Light / Collision Avoidance Light, enclosed please review two brief discriptive sketches of a revised and redesigned CAL-Strobe Alarm Light.

As you can see from these sketches the Collision Avoidance Light and the Strobe Light with its combined LCD-display are housed separately in there own plastic molding cases. The C.A.L. Lamp is the same as it's featured in all vehicles up to date. In the new design the C.A.L. Lamp continues to remain the same with no removal or reconstruction of its original equipment including wiring and chassey.

Only the Strobe lights with it's LCD-display is redesigned to fit in front of the C.A.L. Lamp. By way of a plastic holder or clip the base of the Strobe light with it's LCD-display with measurements and dimensions that have also been redesigned, will allow the unit to fit onto the C.A. Lamp. The Strobe light and LCD-display will not enter into the plastic molding case of the C.A.L. Lamp. Nor will the wiring and circuitry be connected or housed in the same chassey.

The Strobe Light with LCD-display will be an added optional accessory that can be connected to the C.A.L. Lamp by a seperate outer holder or clip.

The Strobe Light with LCD-display and the C.A.L. Lamp will naturally function separately from each other. The Collision Avoidance Light functions only when the vehicle has been turned on and/or is operating in motion. The Strobe Light with LCD-displ ay only functions when the vehicle is parked and the alarm has been actuated by the owner.

The C.A.L. Lamp has and will continue to have wires that will be connected to the brake lights at the rear of the trunk.

The Strobe Alarm with LCD-display has wires that are connected only to the alarm of the vehicle.

The incorporation of a voice actuator that will be heard only when the Strobe light of the car locator is actuated, will be featured by way of a small computer chip. This small computer chip will be safely connected to the strobe light.

Mr. Wood, I have designed these items to make Department of Transportation standards and requirements.

A speedy reply to these concerns would be highly appreciated. I'd like to Thank you once again for your previous reply.

Sincerely

Mark F. Holmes

THE STROBALARM WITH VOICE ACTIVATOR

the strobalarm system is equipped with a LCD-display that allows the car owner not only to verify the status of the alarm after leaving the car, but it also allows the user to register, after someone attempted to brake into the car, thru which door it to ok place. The word status armed will replace the need to have a blinking LCD light that is seen when most car alarms are armed. Also included is a VCL-Voice Locator that speaks to the owner when the strobe light flashes. This design is made possible by a small computer chip that also speaks as a panic signal during emergencies.

the following information is displayed:

alarm: right door

alarm: left door

alarm: trunk

alarm: hood

status: armed

alarm: left window

alarm: right window

the addition of the LCD-display to the strobe alarm not only protect the car better thru a visual warning to the intruder, but it also keeps the car owner informed about the functions of the alarm system. The strobe alarm with it's LCD-display is wired and housed separately and functions independently from the collision avoidance light. The strobe alarm unit itself has measured dimensions that will allow the base of the unit to fit in front of the CAL. The strobe light in both the strobalarm and the strobe car alarm system II should be a double flash unit to attract as much attention as possible.

*the strobe alarm with it's LCD-display has been designed to meet the department of transportation (lighting division) standards and regulations. *

a design project for mark holmes

STROBALARM

(Illustration Omitted)

>>V.C.L.<< strobalarm

(Illustration Omitted)

>>V.C.L.<<

STROBALARM

(Illustration Omitted)

>>V.C.L.<<

strobalarm voice car locator

design by mark f. holmes

The Strobe Car Alarm II

Bottom View (Installation)

(Illustration Omitted)

Collision Avoidance Light

THE STROBE CAR ALARM SYSTEM II

the new strobe car alarm system is equipped with a LCD-display and a LCD arrow to the left and right of the display that allows the car owner not only to verify the status of the alarm after leaving the car, but it also allows the user to register, after someone attempted to brake into the car, thru which door it took place. The word status armed will replace the need to have a blinking LCD light that is seen when most car alarms are armed.

the following information is displayed:

alarm: right door

alarm: left door

alarm: trunk

alarm: hood

status: armed

alarm: left window

alarm: right window

this addition to the strobe alarm does not only protect the car better thru a visual warning to the intruder, but it also keeps the car owner informed about the functions of the alarm system. The strobe alarm with it's LCD-display is wired and housed se parately and functions independently from the collision avoidance light. The strobe alarm unit itself has measured dimensions that will allow the base of the unit to fit in front of the CAL.

*the strobe alarm with it's LCD-display has been designed to meet the department of transportation (lighting division) standards and regulations. *

a design project for mark holmes

The Strobe Car Alarm II

A Design Project by

Mark F. Holmes

The Strobe Car Alarm II

(Illustration Omitted)

Colision Avoidance Light

The Strobe Car Alarm II

(Illustration Omitted)

Collision Avoidance Light

The Strobe Car Alarm II

Collision Avoidance Light

ID: nht90-1.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/09/90

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: HOWARD KOSSOVER -- CMI TRAILER DIVISION

TITLE: NONE

ATTACHMT: LETTER DATED 12/08/89 FROM HOWARD KOSSOVER -- CMI TRAILER DIVISION; OCC 4233

TEXT: Dear Mr. Kossover:

This is in reply to your letter of December 8, 1989, to Taylor Vinson of this Office. You have enclosed photographs of a semi-trailer that you are constructing, and wish to know whether the location of the rear turn signal, stop, and taillamps comply wi th the requirements of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Table II of Standard No. 108 requires each of these lamps to be "on the rear". In addition, the SAE requirements for each of these lamps that are incorporated by reference into Standard No. 108 require that visibility of each lamp shall not be obstructed by any part of the vehicle throughout the photometric test angles for the lamp, unless the lamp is designed to comply with all photometric and visibility requirements with these obstructions considered. In addition, signals from lamps on both sides of the vehicle shall be visible through a horizontal angle from 45 degrees to the left to 45 degrees to the right. To be considered visible, the lamp must provide an unobstructed projected illuminated area of the outer lens surface, excluding reflex, at le ast 2 square inches in extent, measured at 45 degrees to the longitudinal axis of the vehicle.

The lamps on your semi-trailer are mounted 27 inches from the rear of the vehicle. In that position the lamps are not mounted "on the rear". Further, we question whether the 45 degree visibility requirements would be met, especially for the inboard lam ps. We do not know whether the extended portion of the vehicle between the lamps is a sufficient obstruction to affect compliance with the photometric requirements. Overall, it does not appear that this design complies with Standard No. 108.

Sincerely,

ID: nht90-1.100

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 29, 1990

FROM: JERRY W. MOONEY -- RESIDENT AGENT IN CHARGE, DEPT. OF THE TREASURY, U.S. CUSTOMS SERVICE TO: STEVEN WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: FILE SV08PLOSV001

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO JERRY W. MOONEY FROM

STEPHEN P.WOOD; (A35; IMPORT REG.) TEXT:

Our office requests your assistance in an Investigation involving seventeen (17) M151A2 military jeeps illegally imported into the United States from Napierville, Quebec, Canada. S/A Todd Petrie of this office was advised by DOT Compliance Officer, Fred Coutts, to provide you with a written request.

The M151A2 is a quarter ton military jeep first produced for the Department of Defense by A. M. General Division in 1972. The investiga- tion has shown that these vehicles were imported into the country without declaring them as vehicles. The Customs declarations simply stated "miscellaneous jeep parts." No HS-7 declarations were filed. The vehicles were whole, intact jeeps. In addition, the jeeps were concealed inside containers and covered with parts.

To assist in this investigation, please respond to the following:

We are of the understanding that a list does not exist naming certain vehicles as being noncomplying. If not, what is the procedure to determine if a vehicle complies to DOT standards?

We are of the understanding that the M151A2 does not comply to DOT standards. What makes it a noncomplying vehicle?

Does the fact that the M151A2 was manufactured for DOD make it a noncomplying vehicle?

If you have any questions, contact S/A Todd Petrie or me at (912) 944-4341. Your assistance in this matter is greatly appreciated.