Interpretation ID: nht87-1.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Fred E. Maynard

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Fred E. Maynard 13208 Creek Park Lane Poway, CA 92064

Dear Mr. Maynard:

This is in reply to your letter of November 14, 1986, to Taylor Vinson of this Office with respect to an automotive lighting product that you have developed.

According to your letter the VISICOM is an electronic message sending unit which incorporates a center high-mounted stoplamp "which will meet all of the standards required by Regulation 108 as to size, light intensity, angle of visibility, etc.." You hav e asked for an opinion "on any potential current or future legal problems that might arise when this product is marketed."

I will be pleased to discuss the relationship of your device to Federal Motor Vehicle Safety Standard No. 108 and the National Traffic and Motor Vehicle Safety Act, but we cannot advise you of problems you might encounter under State or common law. Stand ard No. 108 covers original vehicle equipment and items manufactured to replace original equipment. Paragraph 54.4 of Standard No. 108 states, in pertinent part, that "...no high-mounted stoplamp shall be combined with any other lamp or reflective device ." In our view, this precludes you from offering the VISICOM as either an original center high-mounted stoplamp, or as one intended to replace such a stoplamp on any passenger car manufactured on or after September 1, 1985.

However, you are not precluded by Standard No. 108 or the Act from offering this device as aftermarket equipment on passenger cars manufactured before September 1, 1985. Whether VISICOM is acceptable on these vehicles must be determined by the laws of ea ch State in which the device will be sold or used.

Thank you for your interest in safety. If you have further questions we would be pleased to answer them.

Sincerely, Erika Z. Jones Chief Counsel

November 14, 1986

Mr. Taylor Vinson, Legal Council NHTSA, Dept. of Transportation 400 7th Street SW

Dear Sir:

I was referred to your office by the people at the D.O.T. 1-800 number as the source for an NHTSA legal opinion concerning an automotive accessory product I have developed. Since one of its functions is somewhat related to the third brakelight now requir ed in 1986 or newer automobiles, but no reference to its total concept is made in Regulation 108, I feel its necessary we have an official opinion on any potential current or future legal problems that might arise when this product is marketed.

I have included a complete functional description of the product as we now intend to manufacture It and I Hill certainly appreciate any suggestions or comments you might have and any reference to other NHTSA regulations that define a product concept like VISICOM if any exist at all.

Thanking you in advance I remain:

Sincerely

Fred E. Maynard 13208 Creek Park Lane Poway, Ca. 92064 (619) 748 5883

VISICOM-Product Description

The VISICOM concept can best be described as an electronic sign or message sending unit. It has a number of potential applications with the most attractive market being that of an automotive accessory. In this configuration It will be sold with a number of preprogrammed words and messages the primary purpose of which will be to enhance the safety aspects of automobile operation and promote a higher degree of courtesy on the road.

Physically the unit comes in two sections. the control panel which mounts on the dashboard of the vehicle, and the display section which is to be positioned in the center of the rear window. According to NHTSA (National Highway Traffic Safety Administrat ion) guidelines, a third brakelight would be located in this area of the vehicle in 1986 or newer cars so in order to avoid any conflict with these regulations, the VISICOM automotive model will be supplied with an integrated third brake light which will meet all of the standards required by NHTSA regulation 108 as to size, light intensity, angle of visibility, etc.. This third brakelight will also serve as the base for the display section of the VISICOM which measures approximately 4"H x 17"L x 3"D. Th is enclosure contains virtually all of the electronic control and programming circuits as well as the display itself which consists of six 14 segment alpha-numeric characters 2.5"W x 3.9 "H. Each segment contains a 1.2 watt incandescent bulb which is ene rgized when that segment is required to form a specific number or letter. The words formed by the segmented characters are displayed one at a time for a duration of the seconds with a half second pause in between until the message is complete. Some of th e messages are automatically activated and some of the others continue repeating until the operator ceases the transmission. The messages contained in the system are as follows:

Automatic Messages One Time Display Messages

1. STOP 1. HELLO 2. TURN ------ 2. THANK YOU 3. TURN ------ 3. HAVE A NICE DAY 4. BACKUP 4. SORRY 5. BYEBYE Driver Activated Repeating 6. OK TO PASS Messages 7. NOT OK TO PASS 8. PLEASE DIM YOUR LIGHTS 1. PLEASE CALL POLICE 9. YOU ARE TOO CLOSE 2. NEED HELP 10. CHILD IN CAR 3. HAZARD AHEAD 11. CHECK YOUR DOORS 4. OUT OF GAS 12. CHECK YOUR TIRES