Interpretation ID: nht90-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 04/19/90

FROM: MICHAEL F. PICKHOLZ -- PANDA TECHNIK PRESIDENT

TO: NHTSA OFFICE OF CHIEF COUNSEL

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/13/90 FROM PAUL JACKSON RICE -- NHTSA TO MICHAEL F. PICKHOLZ -- PANDA TECHNIK; A35; STANDARD 108

TEXT: Panda Technik, the North American agent of GEKA Gunther & Kastl GmbH., Eislingen/Fils, West Germany, is contemplating the distribution of the GEKA early warning panel in the United States. As this is a safety related devise, we respectfully request your evaluation of this product's suitability as a supplemental safety reflector. Our main concern is to insure that no laws or regulations are violated in the use of the GEKA early warning reflector.

Safety reflectors of this type are required, by law, in West Germany and we feel can make a significant contribution in the reduction of nighttime accidents in our roads as well.

The GEKA safety reflector consists of a metal backing plate, to which triangular section reflectors are affixed by means of rivets, to form a square reflector body. The individual reflector elements are assembled so that a pattern of diagonal, alternati ng red and white reflective strips is created (other color combinations can be made available as well). This pattern resembles the similarly alternating red and white stripe reflective tape developed by the NHTSA as a measure to increase the nighttime v isibility of on highway trucks.

The purpose of the GEKA reflector is to enhance nighttime and adverse weather visibility of slow moving/stationary vehicles which may be positioned in a manner which generates a hazard of collision with oncoming traffic. This is accomplished through a r eflective efficiency up to ten (10) times that of conventional reflectors (such as those required by law on all motor vehicles).

The GEKA reflector is intended solely as a supplemental safety devise and will be advertised as such, with specific mention that this is only an auxiliary devise which in no way replaces, supersedes or eliminates required safety devises or safety procedu res.

Applications for which the GEKA safety reflector are considered beneficial are:

* Slow moving trailers/convoys

* Parked or broken down vehicles within or near roadways

* Public Utility vehicles (i.e. utility line trucks, road crews, etc.)

As mentioned, Panda Technik firmly believes the GEKA early warning reflector can make a substantial contribution in the reduction of nighttime accidents through the increase in visibility and presence of slow moving or stationary vehicles.

Furthermore, the GEKA reflector can be installed with simple hand tools on either the front or rear of the vehicle. In cases where the vehicle is transverse to the flow of the traffic (such as line crews performing telephone or electric repairs) the rem ovable version can be positioned in accordance to the direction of traffic flow and which portion(s) of the vehicle is (are) exposed to the risk of collision.

In order to facilitate your evaluation of the GEKA reflector, a sample has been included. This particular model represents a fixed version, to be deployed whenever needed, which remains in the close, protected position, under normal usage.

Thank you in advance for your kind consideration of this matter. Should you have any additional questions, require additional documentation or need further test samples please, do not hesitate to contact Panda Technik.

Sincerely