Interpretation ID: nht91-4.44

DATE: July 9, 1991

FROM: William J. Lewandowski -- National Accounts Manager, Wheels/RV Products, Kelsey-Hayes

TO: Robert Helluth (Hellmuth) -- Director of Vehicle Safety Compliance, NHTSA

COPYEE: M. McGrath; E. Kowalski

TITLE: Stop Lamp Activation - Tekonsha Electric Brake Controllers

ATTACHMT: Attached to letter 5-23-91 from Paul Jackson Rice to Bill Lewandoski; Also attached to letter dated 4-30-91 from Bill Lewandowski to Taylor Vinson; Also attached to letter dated 11-22-91 Paul Jackson Rice to William J. Lewandoski (A38; Std. 108)

TEXT:

Since receiving the May 23, 1991 letter from Paul Jackson Rice regarding trailer stop lamp activation, we have received a CHP (California Highway Patrol) Management Memorandum # 91-80 on the legality of the Tekonsha electric brake controllers and compliance with stop lamps. Evidently, NHTSA has issued more than one ruling on brake controller compliance to regulations regarding trailer stop lamp activation.

We are enclosing the NHTSA letter dated 5-23-91 and the CHP memo dated 5-30-91.

Please provide clarification regarding compliance and/or non-compliance. We will supply any information you require and look forward to your response to this subject.

ATTACHMENT

Management Memorandum No. 91-80 (Expires 11-29-91

To: All Commanders

"TEKONSHA COMMANDER" ELECTRIC TRAILER BRAKES

The National Highway Traffic Safety Administration (NHTSA) has issued a ruling regarding the legality of the "Tekonsha Commander" electric trailer brake. Under NHTSA preemption authority in Title 15, Section 1395(D) U.S. Code, the device and its use are legal.

Department personnel are to consider the Tekonsha Commander electric trailer brake and all similarity designed electric brakes to be in compliance with 24603 VC (stop lamps) and 26458(D) VC (single control exemption) provided that the devices are properly installed and all components are functioning correctly.

OFFICE OF THE COMMISSIONER