Interpretation ID: nht89-2.88

TYPE: INTERPRETATION-NHTSA

DATE: 08/30/89

FROM: JOHN K. MOODY -- MOODY & MOODY ENTERPRISES

TO: TAYLOR VINSON -- LEGAL COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION FMVSS-108 U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/89 FROM STEPHEN P. WOOD -- NHTSA TO JOHN K. MOODY -- MOODY AND MOODY ENTERPRISES; REDBOOK A34; STANDARD 108; LETTER DATED 09/14/89 FROM S. WATANABE -- STANLEY ELECTRIC COMPANY TO STEPHEN P. WOOD NHTSA; OCC 3931

TEXT: Dear Mr. Vinson,

My company is planning to market nationwide a vehicle aftermarket kit which effects the front turn signals on motor vehicles. The intent of this letter is to inquire as to whether or not vehicles equipped with our product would be in conflict with exist ing vehicle lighting standards established by N.H.T.S.A..

Prior to writing this letter I had telephone conversations with several individuals there at N.H.T.S.A. and the consensus was that, since our product does not interfere with the normal operation of the existing vehicle lighting equipment, there would be no conflict. It was recommended, however, that I write this letter to you in order to obtain an official evaluation of our product and to receive a reply in writing.

Our product is really quite simple. We connect both front turn signal lamp filaments so that when the brake pedal is pushed and the rear brake lights are illuminated, both front turn signal lights are also illuminated. If a turn signal is activated eit her before or during application of the brakes, the front turn signal light flashes in its normal manner thereby indicating the direction of turn while the other front turn signal light will be illuminated as long as the brake pedal is being pushed.

This product is intended to add a significant measure of safety to vehicles by providing a forward indication as to whether or not the driver of the vehicle is attempting to apply the brakes. This would be a benefit to other drivers and pedestrians alik e.

According to the directional analysis of 1987 motor vehicle traffic accidents published by the National Safety Council, this safety improvement could have been helpful in reducing 41.6% of all two car accidents (8,652,800) and 29.5% of all two car fatali ties (12774). In addition, we believe that a significant number of pedestrian-car accidents (90,000 total resulting in 8200 fatalities in 1987) could have been avoided had the car been equipped with a forward directed brake application indicator.

Although we are requesting your evaluation concerning our product's compatibility with vehicle lighting standards, we also would appreciate any comments which you or others would offer concerning your opinion as to the safety benefits which would result from vehicles being equipped with a forward directed brake application indicator.

For your information, we are sending a similar letter to each state requesting their opinion concerning our product and their state vehicle lighting regulations.

Thank you for your attention to this matter. A prompt reply would be greatly appreciated.

Sincerely,