Interpretation ID: 11135r

Mr. Charles de Saint Martin
Project Manager
The Fairchild Corporation
P.O. Box 10803
Chantilly, VA 22021

Dear Mr. de Saint Martin:

This replies to your letter of August 10, 1995, with reference to "Securiflash". Taylor Vinson of this Office phoned you on August 21 for a clarification.

We understand that, in the event of a deceleration of 0.8 g, such as caused by emergency braking, "Securiflash" automatically activates a vehicle's hazard warning system lamps; after 5 seconds, the lamps go off.

Enclosed is a copy of a letter that we sent Saline Electronics on April 24, 1995, which provides our views that a deceleration system that operates through the hazard warning system is impermissible under Federal Motor Vehicle Safety Standard No. 108.

However, we are interested in your remark that the product "was developed after different European studies showed that 60 percent of rear end collisions would be avoided if the brakes had been applied one second earlier." We are unaware of such studies, and would like to receive copies of them so that the agency may enhance its knowledge of the conditions under which rear end collisions occur.

If you have any further questions, please call Taylor Vinson at (202) 366-5263.

Sincerely,

John Womack Acting Chief Counsel

Enclosure NCC20:Vinson:6-2992:9-6-95:Lyn OCC# 11135 cc: NCC-0l Subj/Chron NCC-20 Vinson Interps. 108; Redbook (3) U:\ncc20\interp\108\11135r.ztv