Interpretation ID: nht90-4.56

TYPE: Interpretation-NHTSA

DATE: November 8, 1990

FROM: Mitch L. Williams -- President, Hella, Inc.

TO: Richard Van Iderstine -- Office of Vehicle Safety Standards; NHTSA

TITLE: Re Proposed new product from Hella

ATTACHMT: Attached to letter dated 12-24-90 from Paul Jackson Rice to Mitch L. Williams (A37; FMVSS 108); Also attached to letter dated 11-1-90 from Mitch L. Williams to Richard Van Iderstine (OCC 5441)

TEXT:

In addition to my letter to you of November 1, 1990, Hella is considering another new product which could have vehicle safety implications.

As you know, pick-up trucks are not currently required to have a third brake light originally equipped. We feel that adding a third brake light to these vehicles would significantly reduce the chances of rear end collisions for the following reasons:

A) Pick-up trucks are selling in record numbers and are becoming a larger portion of the vehicle population, therefore diluting safety advantages created by adding third rear brake lights to automobiles in 1986.

B) Pick-up trucks are among the most difficult vehicles on the road for a following driver to see around. Any added safety must have a positive effect for following drivers.

Since there are no current regulations on this subject, Hella would like to ask NHTSA's opinion on the following questions:

1) Does NHTSA agree with Hella that a third brake light would be an added safety feature for pick-up trucks?

2) Does NHTSA intend to regulate this subject matter and if so, when and how?

3) The major technical point for us as manufacturers is where to mount the third lamp. The obvious place is on the tailgate, but this presents certain technical problems such as operating the vehicle with the tailgate down, and insuring a good electrical connection with a tailgate which moves. Also a good place is the upper edge of the back window, but for trucks with caps or campers on them, this will not work. Assuming NHTSA will address this area, how will NHTSA view the mount ing location?

Thank you in advance for your consideration.