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TYPE: INTERPRETATION-NHTSA

DATE: 04/18/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Wayne Apple

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/19/89 letter from Stephen P. Wood to Rod Willaredt (A33; Std. 108); 5/17/89 letter from Rod Willaredt to Taylor Vinson; 2/19/88 letter from Erika Z. Jones to Charles Wilson; 7/11/88 letter from Erika Z. Jones to Willaim J. Stephenson

TEXT:

Mr. Wayne Apple 14738 Bronson Avenue San Jose, CA 95124

Dear Mr. Apple:

This is in reply to your letter of December 29. 1987, in which you asked whether a U-Turn Indicator "is reasonable, within federal regulations or specifications, and if the Department of Transportation has interest in the concept and/or product."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment contains specifications for original and replacement lighting equipment. None of these specifications is for a U-Turn indicator. However, a U-Turn indicator is acceptable as original vehicle equipment provided it does not impair the effectiveness of the lighting equipment that the standard requires, such as turn signal lamps, headlamps, taillamps, and stop lamps. Your proposed specifications recognize the i mportance of differentiation between the left turn signal and the U-Turn indicator, and we encourage you to minimize the possibility of impairment.

Standard No. 108 does not cover a U-Turn indicator as an aftermarket device, but it is subject to the general restriction that its installation must not render inoperative, in whole or part, any lamp reflective device, or associated equipment that was in stalled pursuant to Standard No. 108. (15 U.S.C. 1397 (a)(2)(A)) The legibility of use of an aftermarket device of this nature would be determinable under the laws of the State in which a vehicle equipped with it is registered or operated. The American A ssociation of Motor Vehicle Administrators, 1201 Connecticut Ave. N.W., Washington, D.C. 20036 may be able to advise you further on State laws.

Accident data available to the agency does not permit us to identify specific crashes in which a vehicle is making a U-Turn. However, an analysis of data from one of our files that contains information on almost 3 million crashes indicates that the gener al type of crash for which U-Turn crashes are a subset (left-turning crashes) constitutes less than 6% of the total crash experience. Thus, we believe that the number of U-Turn crashes is substantially less than 6% represented by the broader category of crashes involving left-turning vehicles.

We do not know the basis for your statement that your U-turn indicator "will probably reduce accidents involving U-turns by over thirty percent". However, the agency is interested in exploring concepts that could enhance vehicle safety. I am providing ou r Office of Research and Development with a copy of your letter for such further comment as may be warranted.

We appreciate your interest in safety.

Sincerely,

Erika Z. Jones Chief Counsel

CC: Michael Finkelstein

December 29, 1987

Erika Jones, Chief Counsel Legal Office, Room 5219 D.O.T. Headquarters 400 7th Street Southwest Washington D.C. 20590

Dear Erika,

I have been instructed by the Office of Vehicle Compliance to write you concerning a new Safety feature I have designed. I am interested in receiving feedback as to whether my idea is reasonable, within federal regulations or specifications, and if the D epartment of Transportation has interest in the concept and/or product.

The reason I have designed this Safety feature, which is called an Automobile U-turn Directional Indicator was to reduce the number of automobile accidents in which U turns are involved. My sister and several acquaintances, have suffered serious injuries , primarily due to the lack of communication between drivers, simply because they do not have a tool by which to communicate.

The solution is simple and at a very low cost, yet it could save the lives of many.

Please review the attached documentation, and feel free to write or call me if you have any questions or require additional information. Thank you for your time and effort.

Sincerely,

Wayne Apple 14738 Bronson Ave. San Jose, CA 95124 (408) 377-0174 Home (408) 986-2526 Work

AUTOMOBILE U-TURN DIRECTIONAL INDICATOR SAFETY FIRST

Far too many accidents involve U-turns, and most likely they are of a serious nature. The ability to make a U-turn is much too convenient to try to strip away from the American public. A better and simple means of communicating the intention of making a U-turn is in order; and I have the solution. Implementing this simple tool will probably reduce accidents involving U-turns by over thirty percent.

STATEMENT OF PROBLEM

Situation A: You are in you automobile waiting in the left turn lane with or without a signal light. There is an automobile in front of you, and one behind you, waiting as well. When it is time to turn, the car ahead of you starts accelerating through th e turn. You accelerate as well, and so does the car behind you. Suddenly, midway through the turn, the car in front of you whips into a sharp U-turn, without any means of warning. If you are not quick to react, you clip the rear end of the car as it make s it U-turn, sending it into a spin, hopefully avoiding any serious injuries. If you were quick to react, you end up slamming on your brakes and either slide into the car making the U-turn, or have the car behind you crash into your rear end, slamming yo u into the car making the U-turn. Hopefully, no serious injuries result. Had you known the driver was going to make a U-turn all along you would have been prepared for it from the start of the turn. No accident would have resulted.

Situation B: You are driving your automobile down the street and approach an intersection. There is a car with sitting in the oncoming traffic left hand turn lane. They have activated their left hand turn indicator. There are several cars following behin d your car. The oncoming car in the left hand turn lane believing there is enough time to make the turn, and there probably is. You slow down, so do the cars behind you, to allow for the turning car to pass through the intersection. Suddenly the car whip s into a U-turn. There is not enough time to react. Your car crashes into the U-turn car. One or two of the cars behind you crash into your car's rear end. Hopefully no serious injuries result, but they usually do in such circumstances. Had you known the car was planning to make a U-turn initially, you would have applied the brakes harder when the driver first began the turn, and hopefully avoided any accident at all situation C: You are waiting at a four way intersection in your automobile to make a ri ght hand turn. There is a car waiting in the cross traffic left hand turn lane, ahead and to your right, with the left turn indicator blinking brightly. Right hand turns are legal in your state on red lights. There is a break in traffic. You begin to tur n to the right and into the lane. The car in the left hand turn lane begins to turn down the road you had just traveled on. Suddenly, the driver of the car turning left, who was paying more attention to the oncoming traffic, whips the steering wheel hard to make a sharp U-turn, which is legal at this intersection. The two cars collide, crushing the front ends of both automobiles. You would not have made the turn to the right had you suspected the driver of the other car would be making a U-turn.

PRODUCT SOLUTION

The need stated in the problem situations above is a means to notify other drivers when you are planning to make a U-turn, and be able to discern it from a left hand turn signal; thus, I have designed a product with the means to satisfy this need.

The product is an Automobile U-turn Directional Indicator (U-turn Blinker), which is to be mounted on the front and rear driver's side of the car next to the left hand turn indicator. They are to be activated by a four position turn indicator switch, tha t utilizes the fourth down position to activate the U-turn signal. It is recommended that there be additional resistance in moving from the third position (left turn) to the fourth position (U-turn) to alleviate mistakes, as well as a U-turn dash light.

PRODUCT SPECIFICATIONS

* Four position indicator switch. Fourth position down is U-turn. Resistance between third and fourth position.

* The rear U-turn directional indicator light assembly is mounted near the rear left hand turn indicator. The arrow should start at the lower right portion of the light housing, head straight to the top, curve to the left, then point straight downward, a s if the driver trailing the car were looking at a posted U-turn sign.

* The front U-turn directional indicator light assembly is mounted near the front left hand turn indicator. The arrow should start at the upper left hand portion of the light housing, head straight down, bend to the right then head straight up.

PRODUCT SPECIFICATIONS Cont...

* The black area contained within the U-turn light housing assembly which blacks out the portion of the light assembly to outline the arrow, should be painted on, or preferably, be made of black rubber and glued onto the reflector plastic.

* The reflector portion of the U-turn light housing assembly should be a different color than the left hand turn indicator, to better differentiate the two. A cross between yellow and lime green would be noticeable.

* The size and shape of the U-turn directional housing is up to the discretion of the manufacturer, with a minimum of three square inches.

* The intensity of the U-turn indicator light should be equal to, or brighter than, the left hand turn indicator. The color and arrow shape will assist in the differentiation.

* Matching reflector plates can be used on the right side of the car for cosmetics and balance.

* A U-turn dash light indicator should be located near the dash turn indicator light, preferably the same color as the reflector plate.

SUMMARY

Communications between automobile drivers needs to improve. Clearly notifying other driver's your intentions can reduce the number of accidents by over fifty percent. Having the tools to better communicate to other drivers is a necessity. The U-turn dire ctional indicator is one of those tools to making America's roads a safer place.