Interpretation ID: nht80-4.17

DATE: 10/30/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Coded Electronics Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 20, 1980 asking whether your emergency hazard signaling system conforms with Federal Motor Vehicle Safety Standard No. 108. You also asked as to the steps necessary to make it mandatory.

From the specifications provided in your letter, it appears that both modes of operation (hazard and distress) would comply with the flash rates and the percent of current "on" time required by SAE J945, the standard for hazard warning signal flashers incorporated by reference in Standard No. 108. If your device meets all other requirements of SAE J945 and SAE J910, the standard for hazard warning signal operating units also incorporated by reference, it should comply with Standard No. 108.

I am enclosing a copy of 49 CFR Part 552, setting forth the procedures under which you may petition for an amendment of Standard No. 108 that would require a distress signaling system on vehicles.

SINCERELY,

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STATUS OF REPLY / REMARKS

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Based on the times stated in the "Product Specification for the Code II," the flash rates and the percent of current "ON" time will meet the requirements of SAE J945 and FMVSS 108 for both modes. For the hazard signal mode the flash rate will be 70 FPM for a normally closed type flashes and the current ON time is 59%. For the emergency distress signal mode, the flash rate will be 71 FPM for a normally open type flashes with an average current ON time of 65%. SAE J945 requires an average of at least three consecutive cycles. If this flashes meets all the other requirements of SAE J945 and J910, and maintains these flash rates, it should qualify.

John (Illegible Word) 9/23/80

MARKETING & MANUFACTURING DIVISION

CODED ELECTRONICS CORPORATION

August 20, 1980

Frank Berndt Chief Counsel Legal Division N.H.T.S.A.

Dear Mr. Berndt:

During my recent visit to Washington, I met with Taylor Vincent, Attorney, of N.H.T.S.A. Legal Division. The purpose of that meeting was to introduce an inovation to the Emergency Hazard Signaling System, which my company is presently preparing for promotion and distribution throughout the United States and foreign countries. Mr. Vincent was very receptive to the product and suggested that I submit information to you for your review.

Due to the product's specific nature, the primary function does conform to current D.O.T. Standards, however, the secondary function which provides an additional feature, is not regulated by any D.O.T. Specifications. Enclosed, I have provided the product's discriptions, application, and specification. After reviewing this material, it would be greatly appreciated if you could send to me your interpretation of its acceptability and also the steps necessary for Federal Manditory Legislation.

I would like to thank you for your time; and if you have any questions or would like to discuss any facet of the product, please feel free to call me at (415) 441-2411.

Robert A. Belcher President

ENC.

PRODUCT DESCRIPTION

Coded Electronics Corporation is engaged in the manufacturing, marketing and distribution of a Dual Signal Emergency distress and hazard flasher. The flasher is currently called "CODE II" and refered to from time to time as the product.

The product was developed to utilize the existing 4-Way Hazard Flash system standard on most vehicles in use today. The basic feature that the product provides is that a motorist will now have the option to designate his immediate situation as to a "warning," i.e. stopped to read a map, or "stranded/distressed." i.e. out of gas, or illness of some sort.

The distinction between the Hazard signal (primary function) and the Distress signal (secondary function) is simply a variation in the distress mode. Basically the Distress signal is a modification of the International Distress Signal, the "S.O.S." and is described in the specifications, i.e. short flash, long flash, short flash . . .

The product poses the ability to increase auto safety by clearly defining the existing situation of a stopped vehicle with a maximum of visual via the 4-way lights. It also provides the physically handicapped motorist the ability to designate his situation without having to leave his vehicle, and with a minimum of physical effort.

Our recent efforts have us in contact with California Law Enforcement Agencies which are willing to introduce and acknowledge the additional emergency signal provided by the product along with the hazard signal. Also, we are currently in final negotiations with a major National Auto Accessories Distributor and project introduction to the marketplace within the next few months.

PRODUCT APPLICATION

CODE II, Emergency Distress and Hazard Signal Flasher, is applicable to most vehicles with a standard 4-Way Hazard Signal Flash System.

CODE II installs simply by removing the existing Hazard Flasher, placing the CODE II Flasher in the place of the standard flasher and attaching the Signal selection switch provided with the flasher.

CODE II is a state-of-the-art all electronic flasher designed to meet all existing regulations and to exceed them in reliability and dependability.

Simply, CODE II requires no alternation of the electrical system and utilizes the Hazard Flashing Signal as the primary function along with the optional Distress Signal as the secondary function.

PRODUCT SPECIFICATIONS

CODE II

Dual Signal Emergency Distress & Hazard Flasher

HAZARD SIGNAL FLASHER (Primary Function Mode)

A = OFF Time in Seconds (NO FLASH) Sec. 0.36

B = ON Time in Seconds (FLASH) Sec. 0.5

Hazard Signal Flash is within D.O.T. Standards. CODE II also meets and exceeds D.O.T. specifications for reliability.

EMERGENCY DISTRESS SIGNAL FLASHER MODE (Secondary Function)

C = OFF Time in Seconds (NO FLASH) Sec. 0.30

D1 = ON Time in Seconds (FLASH) Sec. 0.36

D2 = ON Time in seconds (FLASH) Sec. 0.92

(Graphics omitted) NOTE: All on and off duration times can vary +/- 10% at most, and can be programmed for any sequence of flashes or any duration of flashes due to its sophisticated electronic design.