Interpretation ID: nht78-2.9

DATE: 06/30/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Christy Electronics, Inc.

COPYEE: AMER. ASSOC. OF MOTOR VEHICLE ADMINISTRATORS

TITLE: FMVSS INTERPRETATION

TEXT: Our regional office in White Plains has forwarded your letter of May 29, 1978, for reply.

You have requested "approval" of your vehicle lighting system which flashes the stop lamps at a rate three times per second when the brake pedal is depressed.

We do not "approve" lighting devices but we do provide interpretations whether such devices are permissible under Federal lighting requirements. As an item of original vehicle equipment your device would appear to be prohibited by paragraph S4.6 of Federal Motor Vehicle Safety Standard No. 108. This paragraph requires that all lamps be steady - burning in operation except for turn signal lamps, hazard warning, signal lamps, and school bus warning lamps, and it also allows headlamps and side marker lamps to be flashed for signalling purposes.

As an aftermarket device, however, it would be subject to regulation by the individual States. We are forwarding a copy of your letter to the American Association of Motor Vehicle Administrators for an opinion on this point.

We appreciate your interest in safety.

Sincerely,

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

June 8, 1978

Frank B. Caristia Christy Electronics, Inc.

Dear Mr. Caristia:

We are forwarding your letter of May 31, 1978 to the National Highway Traffic Safety Administration's Office of Crash Avoidance in Washington D.C. for their review and action.

Irving Rodness Motor Vehicle Program Specialist

CHRISTY ELECTRONICS, INC.

May 29, 1978

National Highway Traffic Safety Administration

Gentlemen:

We hereby request approval of our new product, for vehicular use, with function as described below:

1. When the brake pedal is depressed the stop lights will flash three times, at a rate of approximately three flashes per second, and then remain lit as long as the brake pedal is held depressed.

2. When the brake pedal is released, the stop lights go off and the circuit resets, ready to flash the stop lights when the brake pedal is again depressed.

This rapid flashing of the stop lights is intended as a means of "waking up" the driver of the vehicle behind you when making stops on highways.

In case of product failure, a by-pass switch can be thrown to restore the vehicles original stop light circuitry.

Please note that many drivers pump their brakes to cause the stop lights to flash, risking an accident because of increased stopping distance.

Frank B. Caristia President