ID: nht88-2.39

TYPE: INTERPRETATION-NHTSA

DATE: 06/01/88

FROM: PETER CAMERON-NOTT

TO: ERIKA Z. JONES -- CHIEF COUNSEL D.O.T.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/10/88 TO PETER CAMERON FROM ERIKA Z. JONES, REDBOOK A32; IMPORT REGULATION; LETTER DATED 11/13/86 TO PETER CAMERON FROM FRANCIS ARMSTRONG, NEF 32GSH

TEXT: Dear Ms. Jones,

I would first of all like to thank you for your assistance last year in clarifying certain DOT import regulations.

Once again I need to call upon your assistance. I wish to import an incomplete vehicle that is in kit form. The kit requires complete assembly as well as the purchase of additional parts - which include engine, transmission, drive-shaft, wheels, tires and seat belts here in the U.S.

I understand from a previous letter (copy enclosed) that a vehicle imported in kit form requires that certain items must be FMVSS certified at time of importation. The kit includes items #106,116,205 and all of these carry the appropriate DOT certificat ion markings. Items #109,209, 211 and 213 will be purchased here in the U.S.

My question is can these items be entered with Customs on form HS7 under box #2 as they conform with the FMVSS standards listed in the attached letter.

Your assistance in this matter will be greatly appreciated.

Sincerely,

ENCLOSURE

ID: nht88-2.4

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/88

FROM: JAY V. WRIGHT -- PAGE AVJET CORPORATION

TO: CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/11/88 TO JAY V. WRIGHT FROM ERIKA Z. JONES, REDBOOK A32(2), STANDARD 102(3)

TEXT: Dear Sir:

The Engineering and Aerospace Division, Page Avjet Corporation, manufactures and markets an aircraft fuel servicing unit referred to as a "Hydrant Truck". The unit is used to filter and meter aircraft fuels as fuel is pumped from airport storage into aircraft.

The Hydrant Truck is an assembly of an 11000 lb GVWR cab-chassis and an equipment platform mounted with the accessories necessary to perform its function. The assembly may or may not have a personnel lift attached depending on the size and type of ai rcraft it is intended to service.

The Hydrant Truck is mobile and may well be moved under its own power at its airport base. It is not a unit that is perceived as being moved over public roads or from airport to airport in its daily use.

We believe that because the Hydrant Truck is designed for use at a particular and very restricted type of installation it should not be considered a motor vehicle.

We respectfully request that a ruling be made as to whether the completed unit does comprise a motor vehicle under the Federal Motor Vehicle Safety Standards.

We thank you for your consideration in this matter.

Very Truly Yours,

[BROCHURE]

Aircraft Hydrant Service Vehicle 750 GPM Flow Rate

4 Models Available Specifications:

Chassis

GMC 3500 Series 1-Ton or Ford F350 1-Ton. Back-up alarm. 3 speed automatic w/oil cooler or 4 speed standard transmission. Standard equipment includes: amber beacon, twin spotlights and radio wiring/antenna.

Wide Body Lift Electro/hydraulic operation. 2 ea fueling nozzles to customer's specs. Deadman control.

Thiem Industries Primary and Secondary Pressure/Flow Control Systems provide smooth operation and accurate control.

Pressure/Volume Control System

Primary--Pressure Control Hydrant coupler to customer's specs. Thiem or J. C. Carter. Secondary--Thiem F370ACDE control valve w/Thiem F540-1 rate of flow pilot.

Filter/Separator

3-L model WAH2844 750 GPM. ASME vessel. IAW API 1581 Class C, Group II. Velcon coalescer and separator elements. Thiem F716CDE electronic water sump control. Pressure relief valve. Armstrong air eliminator. Gammon differential pressure gauge.

Extend Unit Service Life Rechassis the Compact, Modular Designed Fueling System.

The Fueling Module is designed to accept Ford, GMC, or Chevrolet 1-ton chassis. Bolt-on mounting allows quick replacement of a worn or damaged chassis. A cost effective alternative to replacing the complete unit.

Page Avjet's Engineering Division manufactures airline ground support and fueling equipment to customer specifications and refurbishes ground support equipment for civilian operators and the U.S. Government.

Detailed Specifications

PAHT-750-1

PAHT-750-2

PAHT-750-4

PAHT-750-8

Chassis

GMC 3500 Series 1-Ton or Ford F350 1-Ton 159.5" Wheel Base Auxiliary Springs/15,000 lb. Rear Axle Dual Rear Wheels Power Steering Power Brakes Dual Gas Tanks (GMC) Dual Batteris w/Isolator Heavy Duty Radiator 8.25 CFM Air Compressor Brakemaster Air Dryer w/Heater 3 ea 9.5" x 27" Air Reservoirs Air Filter Front Discharge Spark Arresting Muffler Back-up Alarm Hobbs Hour Meter Air System Pressure Gauge Interlock Warning Light 6 Cylinder or 8 Cylinder Engine 3 Speed Automatic w/Oil Cooler or 4 Speed Standard Transmission

Fueling System Type III Hydrant System 750 GPM Maximum Flow Primary and Secondary Pressure Controls Aluminum and Stainless Steel Plumbing Aluminum, Stainless Steel and Brass Components Deadman Control System Fuel Nozzle and Lift Interlock System Lighted Control Panel(s) Water Detection System Greer Bladder Type Surge Suppressor 20 Gal. Aluminum Waste Tank/w/Level Gauge Fuel Temperature Indicator Vapor Proof Electrical System Gammon Fuel Sampling Kits Emergency Fuel Shut Off Valves

Fuel Meter Liquid Controls - M60E-2 Fuel Meter Lightened Register and Printer to Customer's Specs.

Filter/Separator 3-L Model WAH2844 750 GPM ASME Vessel, IAW API 1581 Class C, Group II Velcon Coalescer and Separator Elements Thiem F716CDE Electronic Water Sump Control Pressure Relief Valve Armstrong Air Eliminator Gammon Differential Pressure Gauge

Pressure/Volume Control System Primary - Pressure Control Hydrant Coupler to Customer's Specs. (Thiem or J. C. Carter) Secondary -- Thiem F370ACDE Control Valve w/Thiem F540-1 Rate of Flow Pilot

Hoses, Reels, Nozzles 2 1/2" Certified Aircraft Fueling Hoses Hannay EPJ328-35-36RT Hose Reels 12V DC Electric Rewind w/50A Circuit Breakers OPW Swivels Servicing Nozzles to Customer's Specs. (Thiem or J. C. Carter) Twinweld Deadman Hose w/Thiem 13024KB Deadman Control Mounted on Hannay 617-19-20CTR, Spring Rewind Reel Twinweld Fuel/Air Sense Lines w/Quick Disconnects Mounted on Hannay 617-19-20CTR Spring Rewind Reel Hannay HGR100-100 Spring Rewind Static Ground Reels w/100' Cable and 100 Amp Clamp

Control Panel Lighted for Night Operation Nozzle Pressure Gauge w/Calibration Tap Gammon Differential Pressure Gauge Primary & Secondary Control Air Pressure Regulators (Tamper Proof w/Removable Key) Primary & Secondary Control Air Pressure Gauges Water Detection Indicator Light Emergency Interlock Override Valve

Page Model 43524 Wide Body Lift Electro/Hydraulic Operation 2 ea 2 1/2" x 11' Certified A/C Fueling Hoses 2 ea Fueling Nozzles to Customer's Specs. Deadman Control System Nozzle Holders w/Interlocks Lighted Control Panel Mast Interlock Switch Maximum Extension Interlock Switch Jammed Mast Limit Switch Work Light 36" x 96" Fueling Platform w/Safety Rails 500 lb. Capacity Emergency Down Valve

Additional Fire Extinguishers to Customer's Specs. Static Grounding Reels & Cables to Customer's Specs. Vehicle Finish Painted to Customer's Specs.

Vehicle Configuration Single Side Mounted Dual Rear Mounted Elevating Platform Service Hose & Reel Service Hoses & Reels w/2 Service Hoses X X X X

PAHT-750-1

*PAHT-750-4

PAHT-750-8

* Model 43524 Elevating Platform may be added to this vehicle if needed at a later date.

Note: The PAHT-750-2 is a 4 wheel trailer mounted unit and may be ordered in any of the above configurations.

**All models can be ordered with custom specifications.

Standard features include 2-way radio antenna system and amber rotating beacon.

ID: nht88-2.40

TYPE: INTERPRETATION-NHTSA

DATE: 06/01/88

FROM: EARL W. DAHL -- THE GOODYEAR TIRE AND RUBBER COMPANY

TO: ERIKA Z JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER 08/26/88 TO EARL DAHL FROM ERIKA Z. JONES, REDBOOK A32, PART 574

TEXT: Dear Ms Jones

This letter concerns the tire identification and recordkeeping requirements of Title 49 Code of Federal Regulations Part 574, Section 574.5 (Figure 1). Note 1 in Figure 1 requires that the characters used in the Tire Identification Number must be Futura Bold, Modified, Condensed or Gothic. However, Note 4 of Figure 1 states that other print type will be permitted if approved by the administration.

The Goodyear Tire & Rubber Company wishes to use the style of characters shown in the attached drawing ED1087409 to fulfill the requirements of 49CFR574. These characters are engraved in the mold rather than stamped. We request a letter of approval if N HTSA finds that these characters meet the objective of being "easily readable." (35 FR 17258, November 10, 1970).

We will appreciate your prompt consideration of this request.

ATTACHMENT

Sincerely

ID: nht88-2.41

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 2, 1988

FROM: C. W. PIERSON -- LORD AND PIERSON

TO: ERIKA Z. JONES -- CHIEF COUNSEL, DOT

TITLE: DOT REQUIREMENTS FOR TESTING OF SEATS (AUTOMOTIVE, TRACK, BUS, MASS TRANSIT).

ATTACHMT: LETTER DATED 10-17-88 TO CHARLES W. PIERSON FROM ERIKA Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: Lately the government has been requiring more "dynamic" testing over "static" testing. This leads to broad interpretation (or mis-interpretation) by engineers like myself, and I think the loopholes should be closed.

For example, if you say a headrest shall be pull-tested at a load of 200 pounds (49USC-202-S4-b4ii) it leaves very little to the imagination. But if you say ". . . during the 10 g deceleration the H.I.C. number shall not exceed 400 for passengers ran ging in size from a six year old through a 95 percentile male" (49USC-1601-2.3.2.4-1), you set up a number of variables.

1. Are you using Dreyfus' (M.I.T.) standard man, or NASA's standard man? (Personally J use Barnes standard man-he is between the two). Have you visited a 6th grade class lately to see the size spread? I chaperoned a recent Chicago trip and the age r ange was 10 through 14!

2. The University of Michigan crash tests, but will NOT certify the results.

3. Laws requiring certification usually do not require the actual crash test to be performed.

4. Where do I get SAE Recommended Practice J833? It is NOT readily available!

5. The Formula:

(SEE ILLUSTRATION ON ORIGINAL)

. . . really can be mis-calculated and the results mis-interpreted, because you are putting variables in.

As you can see, a fixed number eliminates guesswork. Anyone can understand it, and over the years I've reached the conclusion that only about half of the engineers have a real live college degree, (I'm a Western grad!)

ID: nht88-2.42

TYPE: INTERPRETATION-NHTSA

DATE: 06/02/88

FROM: STEVEN CROWELL

TO: ELIZABETH DENNISTON -- DIR. OF COMMUNICATIONS; EGON BITTNER COMMISSIONER-WALTHAM, MA.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA TO WILLIAM D. FALCON; REDBOOK A35; STANDARD 201; 202; 205; VSA 108[A][2][A]; LETTER DATED 01/30/89 FROM WILLIAM D. FALCON TO RALPH HITCHCOCK -- NHTSA; OCC 3107; LETTER FROM STEVE C ROWELL; DATED 11/02/88 EST

TEXT: Commission on Accredidation for Law Enforcement Agencies Inc. 4242b Chain Bridge Rd. Fairfax, Va 22030

Dear Ms. Denniston, Mr. Bittner and Mr. Medeiros;

The automobile interior partitions used in all cruisers I have observed seem to lack some legal requirements.

The Motor Vehicle Safety At of 1966 (U.S. Public Law 89-563) sets forth the following requirements;

49 CFR Ch.V (10/1/86 Edition)

** Sect. 567.7 Requirements For Persons Who Alter Certified Vehicles- A person who alters a vehicle that previously has been certified in accordance with sect 567.4 or 567.5 . . . . shall allow the original certification label to remain on the vehicle , and shall affix to the vehicle an additional label . . . . containing the following information: "This vehicle was altered by (individual or corporate name) in (month and year in which alterations were completed) and as altered it conforms to all appli cable Federal Motor Vehicle Safety Standards affected by the alteration and in effect in (month, year).

** Sect. 571.107 Standard No. 107; Reflecting Surfaces. This standard specifies reflecting surface requirements for certain vehicle components in the driver's field of view.

** Sect 571.111 Standard 111; Rearview mirrors. This standard specifies requirements for the performance and location of rearview mirrors . . . to reduce the number of deaths and injuries that occur when the driver does not have a clear and reasonabl y unobstructed view to the rear.

** Sect. 571.201 Standard No. 201; Occupant protection in interior impact. This standard specifies requirements to afford impact protection for occupants. s3.2 Seat backs-when that area of the seat back that is within the head impact area (head impact area means all nonglazed surfaces of the interior of a vehicle that are statically contactable by a 6.5-inch dimeter spherical head form of a measuring device having a pivot point to "top of head" dimension infinitely adjustable from 29 to 33 inches in accordance with the following proceedure etc.).

** Sect 571.205 Standard No. 205; This standard specifies requirements for glazing materials for use in motor vehicles and motor vehicle equipment. The purpose of this standard is to reduce the injuries resulting from impact to glazing surfaces, to e nsure a necessary degree of transparency in motor vehicle windows for driver visibility, and to minimize the possibility of occupants being thrown through the vehicle windows in collisions. S5.1.1.3 the following locations are added to the lists specifi ed in ANS Z26 in which item 6 and item 7 safety glazing may be used: (k.1.1.2 Interior partitions).

Your prompt response to my letter of 1/4/88 is greatly appreciated, however I have noticed a slight oversight in Standard 71.4.1 Transport Equipment. Specifically the mention of wire mesh in this recommendation for the use of a "Safety Barrier". To i dentify an interior partiton (the words used by the D.O.T. for this device) as a "safety barrier" is an oxymoron given the safety hazards inherent in the designs currently being used.

Statistics on bodily injury losses occuring in cruisers seem difficult to obtain, but not so for cabs. The graphs enclosed indicate that when and where interior partitions are used in taxis there is enhanced retention of control for the operation of the vehicle accompanied by epidemic increase in accident fatality and bodily injury loss. It seems that the only way to incur more accident fatality in fewer accidents and more injury with less property damage is to introduce occupant impact hazards.

It is my belief that enhancement in the design of interior partitions will still afford the safety of enhanced operator retention of control and additionally reduce the likelyhood of injury to occupants (front or rear compartments) in the event of a s udden stop or collision.

The economic impact of these hazards in the taxi industry in Boston has been astronomical. Prior to the use of interior partitions in Boston taxis (from 1950-1970) the cost of insurance for taxis was only twice that of the cost for private vehicles i n Boston (given that

ID: nht88-2.43

TYPE: INTERPRETATION-NHTSA

DATE: 06/03/88

FROM: WILLIAM J. HENRICK -- GENERAL TIRE ASSISTANT GENERAL COUNSEL

TO: ERIKA JONES -- NHTSA OFFICE OF CHIEF COUNSEL

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO WILLIAM J HENRICK; REDBOOK A32, PART 574

TEXT: Gentlemen:

This company has reached an agreement with two foreign manufacturers of tires to jointly produce a radial medium truck tire. The facility used to produce this tire will be an expansion of one of this company's facilities in the U. S. of America.

It is contemplated that the same green or uncured tires will be used by all three entities. However, the sidewall will reflect the member company's name.

This letter is a request to confirm our interpretation of 49 CFR 574.6. We believe that each member company may under the regulation secure its own identification mark for use in the curing process. Of course, it is understood that compliance with s ubsections (a), (b) and (c) of part 574.6 would be required.

ID: nht88-2.44

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 7, 1988

FROM: WILLIAM SHAPIRO -- MANAGER -- REGULATIONS AND COMPLIANCE, VOLVO

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: FEDERAL MOTOR VEHICLE SAFETY STANDARD NUMBER 106; BRAKE HOSES-REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO MEMO DATED 12-9-88, TO WILLIAM SHAPIRO, FROM ERIKA Z. JONES -- NHTSA, STD 106

TEXT: Section 5.3 sets forth the test requirements for hydraulic brake hoses. This section states that:

"A hydraulic brake hose assembly or appropriate part thereof shall be capable of meeting any of the requirements set forth under this heading, . . . However, a particular hose assembly or appropriate part thereof need not meet further requirements aft er having been subjected to and having met the constriction requirement (S5.3.1) and any one of the requirements specified in S5.3.2 through S5.3.11."

Sections S5.3.3 and S6.3 speak to the Whip Resistance Test. Table 11 in Section S6.3.1 specifies slack for different hose configurations. In Table 11 for a hose "over 19 to 24 inches inclusive", and "more than 1/8 inch or 3mm." there is no slack specif ied and therefore no requirement in the standard.

Volvo believes that the correct interpretation of this standard, for a hose that falls into the category of over 19 to 24 inches, inclusive, and more than 1/8 inch or 3mm. in diameter is that, while it must meet or exceed the constriction requirement, an d any one other of the requirements in Section S5.3, it need not be tested to meet or exceed the whip resistance requirement to be in compliance with FMVSS 106. Please confirm this for us.

Thank you for your attention to this matter. If you require any additional information, please feel free to contact me.

ID: nht88-2.45

TYPE: INTERPRETATION-NHTSA

DATE: 06/08/88

FROM: LACY H. THORNBURG -- ATTORNEY GENERAL; MABEL Y. BULLOCK -- ASSISTANT ATTORNEY GENERAL NORTH CAROLINA

TO: SUSAN SCHRUTH -- NATIONAL HIGHWAY AND TRAFFIC SAFETY ADMINISTRATION SAFETY ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: WINDOW TINTING; FEDERAL PRE-EMPTION OF STATE REGULATIONS

ATTACHMT: ATTACHED TO LETTER DATED 04/13/89 FROM ERIKA Z. JONES -- NHTSA TO MABEL Y. BULLOCK, REDBOOK A33, STANDARD 215, VSA 103 (D), VSA SECTION 108 (A)(2)(A); LETTER DATED 12/18/87 FROM LACY H. THORNBURG AND MABEL Y. BULLOCK, SUBJECT MOTOR VEHICLES, RE GULATIONS OF DARK SHADED WINDOWS; PREEMPTION; LETTER DATED 05/06/88 FROM DAIRL BRAGG TO WILLIAM S. HIATT; LETTER DATED 10/28/82 FROM FRANK BERNDT -- NHTSA TO LAWRENCE T. HIROHATA, N0A-30; LETTER DATED 04/04/85 FROM JEFFREY R. MILLER TO ARMOND CARDARELLI; REGULATIONS DATED 07/01/85 EST, FEDERAL AUTO SAFETY LAWS AND MOTOR VEHICLE WINDOW TINTING

TEXT: Dear Susan:

It has taken a little longer than I anticipated to get this letter to you. I appreciate your taking the time to talk with me on the several occasions that I have called to discuss window tinting with you.

I have enclosed a copy of North Carolina's statute regulating window tinting and a copy of the regulations filed pursuant to the statute. I have also enclosed an Attorney General opinion interpreting the statute, recent correspondence from Mr. Daryll Bragg and past correspondence from various NHTSA representatives.

My position is that because our statute regulates both owner-operator of motor vehicles with window tinting and manufacturers of such window tinting material, it would be pre-empted by federal regulation if it allows a light transmittance requirement other than 70%.

North Carolina General Statute 20-127(f) regulates what type of tinted film the manufacturer is allowed to make available for installation on a motor vehicle in North Carolina. It seems that the wording in 15 USC @ 1391(4) and 15 USC @ 1397 (a)(2)(A) would preempt our state statute if less than 70% light transmittance in window tinting material was permitted -- based on the regulation of the manufacturer, not the operation of the motor vehicle.

Please let me know your interpretation of this matter. As I interpret past correspondence from NHTSA, it is your agency's position that the federal regulations do cover after-market tinting on used motor vehicles. If you would like to discuss this m atter further by telephone, please call be at (919) 733-3254. Your assistance in this matter would be greatly appreciated.

(North Carolina statute omitted.) Sincerely,

ENCLOSURES

ID: nht88-2.46

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/88

FROM: L. F. ROLLIN COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TO: JERRY K. YOST -- JERRY'S SERVICE

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DOUGLAS H BOSCO, FROM ERIKA Z JONES, REDBOOK A32 (2) STANDARD 108; LETTER DATED 06/16/88, TO ERIKA Z. JONES, FROM DOUGLAS H. BOSCO; LETTER DATED 08/03/87 TO DOUGLAS H. BOSCO FROM ERIKA Z. JONES; LETTER DATED 03/28/88 TO C-MORE-LITE JERRYS SERVICE FROM DON O. HORNING RE TEST REPORT NO 92606; 1988 LETTER TO ERIKA Z. JONES FROM JERRY'S SERVICE

TEXT: Dear Mr. Yost:

This letter is in response to your inquiry about the legality of the C-More-Light headlight device.

My engineering staff reviewed your letter, the letter from NHTSA and the test report (#92606) from Industrial Testing Laboratories (ITL). It is our opinion that the device is legal to install and use on any headlight system designed to meet type "F" pho tometrics. This system is also permitted by California law as long as the photometric output is within the standards established for any other type of headlight. The ITL tests appear to show compliance.

Vehicles equipped with the C-More-Light and a control group of similar vehicles without the C-More-Light device should be used in field testing. Responses from drivers should address the effectiveness of the headlights on both high and low beam as well as the reactions of approaching drivers. Reactions such as flashing high beams or other indicators that the headlights are annoying should be noted. Effective testing should ensure that the test and control group vehicles have properly adjusted headlig hts and that the driver's responses are not prejudiced (not informing the drivers which vehicles have operational C-More-Light devices). We look forward to seeing a report on your test results.

Any further questions should be directed to my engineering staff.

Very truly yours,

ID: nht88-2.47

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/88

FROM: LARRY P. EGLEY

TO: LEWIS BUCHANAN -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION, SUDDEN STOP FLASHER [SSF]; REPORT DATED 09 /07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/20/88 FROM LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199

TEXT: Dear Mr. Buchanan:

I have invented a concept which I believe could significantly improve automobile safety. I call this concept the Sudden Stop Flasher (SSF).

The SSF would work in conjunction with standard automobile brake lights. During the routine deceleration range, the brake lights would function normally. However, at an unusually high braking deceleration rate, such as when the driver suddenly sees a dog on the road or an accident ahead, the SSF system would utilize a pendulum-type decelerometer in conjunction with a special high-speed flasher to rapidly flash the brake lights automatically (such as drivers sometimes try to do themselves but only whe n they have time!).

To increase the effective flash rate, and the "attention-getting index," the high-mount light would flash in rapid sequence with the two lower brake lights, the latter two flashing simualtanously.

I believe this concept would be especially effective in preventing high-speed crashes such as on an Interstate highway when separation intervals are greater and when rapid deceleration may be completely unexpected. These crashes too frequently result in ruptured gas tanks and fatalities.

The SSF would also be especially applicable, I believe, to sutomobiles with anti-skid brakes, because of their superior braking performance. While anti-skid brakes may be highly effective, ironically, automobiles without anti-skid brakes travelling b ehind them may crash into them because of inferior braking performance.

With or without anti-skid braking involved, however, the automatic signal that a high-deceleration slowdown or stop is occuring up ahead could often provide the critical second or two of advance warning which could be the difference between a safe sto p and disaster.

Patent application activity is in progress. However, before I invest more money to develop this concept, I want to be reasonably sure it is not likely to be categorically disapproved by NHTSA. While I do not expect approval, of course, based on only a general description, I would very much appreciate your preliminary comments concerning the prospects of this concept, as well as any related advice you may have to offer.

Because patent activity is in progress, I would appreciate reasonable confidentially.

I would hope to receive a reply from you within 30 days of this date, June 9, 1988.

Thank you very much for your attention.