Interpretation ID: nht93-6.9
DATE: August 12, 1993
FROM: Joe de Sousa -- President, Safety Pro's International, Inc.
TO: Richard Van Iderstine -- NHTSA
TITLE: None
ATTACHMT: Attached to letter dated 3/10/94 from John Womack to Joe de Sousa (A42; Std. 108) and letter dated 8/12/93 from Joe de Sousa to NHTSA Office of Chief Counsel (OCC-8998)
TEXT:
It was a pleasure speaking with you yesterday and we really appreciate the time you devoted in answering our questions and concerns on Regulation 108.
As we discussed in our conversation, the systems we market operate strictly on low beam headlamps. They are connected in parallel to the existing vehicle's lighting and no wires are required to be cut. This preserves the full integrity of the vehicle's system and keeps it fully operational.
The manufacturer of these products believes there is no compromise when dealing with safety and has designed our units for dependability and to eliminate any possibility of malfunction which might cause a safety hazard.
Available is a basic Daytime Running Lights unit which provides for intensity reduction down to 77% of full low beam. It turns on and off with the ignition and is deactivated when all vehicle lights are turned on by the vehicle light switch. A four second delay is featured when turning the engine on to provide maximum energy to the starter. A parking brake cut off can be connected, if desired, to deactivate daytime running lights when the vehicle is idle at night with the engine running and lights are not needed.
Our completely automated system utilizes all the features of our basic unit. Additionally, it incorporates a light sensor and interlocks with the vehicle's windshield wipers to provide complete automatic operation of all vehicle lights with no driver intervention. Like our other unit, the vehicle's original system remains fully operational as a back-up and overrides our unit when activated.
As you will notice in the enclosed information, we've tried to provide a quality line of products designed for safety, durability and convenience.
The installation can be done by anyone with mechanical aptitude or any technician. The average installation time for the basic unit is about 20 minutes while our fully automated system requires about one hour to install. Currently, we are forming a national network of dealers to facilitate installations.
If you would like to see a demonstration on these units, we would be glad to schedule our representative in the Washington D.C. area to stop by and show you how they actually work on a vehicle.
Again, thank you for all your help. If we can ever be of service to your administration, please do not hesitate to call us.