ID: 7418-2

Mr. Trevor Buttle, Project 4
Southam Drive
Kineton Road Industrial Estate
Southam, Leamington Spa,
Warwickshire, CV33 OFA England

Dear Mr. Buttle:

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You requested clarification of the standard's requirement that certain information be displayed "in view of the driver." You also asked whether the display must be permanently illuminated. Your questions are responded to below.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

For vehicles with automatic transmissions, Standard No. 102 requires that identification of shift lever positions, including the positions in relation to each other and the position selected, must be displayed "in view of the driver" at specified times. See S3.1.4 through S3.1.4.4. For vehicles with manual transmissions, the standard requires that identification of the shift lever pattern of manual transmissions, except three forward speed manual transmissions having the standard "H" pattern, must be displayed "in view of the driver" at specified times. See S3.2.

You stated that you believe that the requirement for certain information to be displayed "in view of the driver" relates to the 95 percent eye range contour, hence requiring a display on or near to the "instrument binacle." You asked whether this is correct, or whether floor shift identification is sufficient.

NHTSA has previously addressed Standard No. 102's requirement that certain information be displayed "in view of the driver" in connection with a request for interpretation concerning the identification of the shift lever pattern of manual transmissions. The agency concluded that the pattern "is deemed to be `displayed in view of the driver' if part of it may be seen from the driver's normal eye position and a reasonable amount of movement of the driver allows him to gain full view of the pattern." (Letter to Daimler-Benz of North America, February 27, 1967.) Thus, the information required by Standard No. 102 to be displayed in view of the driver may be displayed on the instrument panel, floor console, or other locations, so long as these criteria are satisfied.

Your second question asked whether the information required to be displayed by Standard No. 102 must be permanently illuminated for night usage. You stated that some auto makers have made this facility switchable.

NHTSA's requirements concerning the illumination of motor vehicle controls and displays are set forth in Standard No. 101, Controls and Displays. S5.3.1 of the standard requires that if a gauge is listed in column 1 of Table 2 and accompanied by the word "yes" in column 5, then the gauge and its identification must be illuminated whenever the ignition switch and/or the headlamps are activated. The last gauge listed in Table 2 is "automatic gear position," and the word "yes" appears in column 5. Therefore, automatic gear position gauges, i.e., the gauges which provide the information required by Standard No. 102 to be displayed for automatic transmission vehicles, are subject to Standard No. 101's illumination requirement.

Under S5.3.3 of Standard No. 101, an automatic gear position gauge may have levels of brightness at which the gauge and its identification are not visible. It is common, for example, for manufacturers to provide a variable light intensity control that enables the driver to turn the illumination for conventional automatic gear position gauges down to off.

It is important, however, to distinguish between turning the illumination off i.e., no illunimation, but display still visible, and adjusting the gauge itself in a way that it no longer displays the required information. As indicated above, Standard No. 102 requires that certain gear position information be displayed in view of the driver at specified times. This requirement would not be met if it were possible for the driver to adjust the automatic gear position gauge in a way that it no longer displayed the required information during the specified times. An example of this would be an electronic gauge using light emitting diodes, where the driver, while driving, could turn the electronic display down to the off level. In this instance, the gauge would not be displaying the required information.

I hope this responds to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:101#102 d:8/13/92

ID: nht92-5.3

DATE: August 1, 1992 EST

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Trevor Buttle -- Project P4

TITLE: None

ATTACHMT: Attached to letter dated 6/22/92 from Trevor J. Buttle to Office of Chief Council, US DOT (OCC 7418)

TEXT:

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You requested clarification of the standard's requirement that certain information be displayed "in view of the driver." You also asked whether the display must be permanently illuminated. Your questions are responded to below.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

For vehicles with automatic transmissions, standard No. 102 requires that identification of shift lever positions, including the positions in relation to each other and the position selected, must be displayed "in view of the driver" at specified times. See S3.1.4 through S3.1.4.4. For vehicles with manual transmissions, the standard requires that identification of the shift lever pattern of manual transmissions, except three forward speed manual transmissions having the standard "H" pattern, must be displayed "in view of the driver" at specified times. See S3.2.

You stated that you believe that the requirement for certain information to be displayed "in view of the driver" relates to the 95 percent eye range contour, hence requiring a display on or near to the "instrument binacle." You asked whether this is correct, or whether floor shift identification is sufficient.

NHTSA has previously addressed Standard No. 102's requirement that certain information be displayed "in view of the driver" in connection with a request for interpretation concerning the identification of the shift lever pattern of manual transmissions. The agency concluded that the pattern "is deemed to be 'displayed in view of the driver' if part of it may be seen from the driver's normal eye position and a reasonable amount of movement of the driver allows him to gain full view of the pattern." (Letter to Daimler-Benz of North America, February 27, 1967.) Thus, the information required by Standard No. 102 to be displayed in view of the driver may be displayed on the instrument panel, floor console, or other locations, so long as these criteria are satisfied.

Your second question asked whether the information required to be displayed by Standard No. 102 must be permanently illuminated for night usage. You stated that some auto makers have made this facility switchable.

NHTSA's requirements concerning the illumination of motor vehicle controls and displays are set forth in Standard No. 101, Controls and Displays. S5.3.1 of the standard requires that if a gauge is listed in column 1 of Table 2 and accompanied by the word "yes" in column 5, then the gauge and its identification must be illuminated whenever the ignition switch and/or the headlamps are activated. The last gauge listed in Table 2 is "automatic gear position," and the word "yes" appears in column 5. Therefore, automatic gear position gauges, i.e., the gauges which provide the information required by Standard No. 102 to be displayed for automatic transmission vehicles, are subject to Standard No. 101's illumination requirement.

Under S5.3.3 of Standard No. 101, an automatic gear position gauge may have levels of brightness at which the gauge and its identification are not visible. It is common, for example, for manufacturers to provide a variable light intensity control that enables the driver to turn the illumination for conventional automatic gear position gauges down to off.

It is important, however, to distinguish between turning the illumination off i.e., no illunimation, but display still visible, and adjusting the gauge itself in a way that it no longer displays the required information. As indicated above, Standard No. 102 requires that certain gear position information be displayed in view of the driver at specified times. This requirement would not be met if it were possible for the driver to adjust the automatic gear position gauge in a way that it no longer displayed the required information during the specified times. An example of this would be an electronic gauge using light emitting diodes, where the driver, while driving, could turn the electronic display down to the off level. In this instance, the gauge would not be displaying the required information.

I hope this responds to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

ID: nht95-1.9

TYPE: INTERPRETATION-NHTSA

DATE: January 4, 1995

FROM: Courtney M. Price -- Reid & Priest

TO: Philip R. Recht -- Chief Counsel, NHTSA

TITLE: Request for Interpretation/Brake Locker

ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO COURTNEY M. PRICE (REDBOOK(4)); Part 567.7; STD. 105

TEXT: On behalf of Maatzorit Ltd. ("Maatzorit"), I am writing to request confirmation of Maatzorit's interpretation of Federal Motor Vehicle Safety Standard ("FMVSS") 105, Hydraulic Brake Systems; FMVSS 106, Brake Hoses; and Section 108(a)(2)(A) of the Nationa l Traffic and Motor Vehicle Safety Act ("Safety Act") (15 U.S.C. 1397(a)(2)(A)) as they relate to the BRAKE LOCKER (U.S. Patent No. 5,375,684) which Maatzorit has developed and will market. n1 Specifically, we are requesting confirmation that installatio n of the BRAKE LOCKER is not precluded by FMVSS 105 or Section 108(a)(2)(A) of the Safety Act. We understand that the National Highway Traffic Safety Administration ("NHTSA") does not give approval of or certify devices such as the BRAKE LOCKER and that confirmation of Maatzorit's interpretation will be based upon the information provided and the circumstances described herein.

n1 FMVSS 105 and FMVSS 106 specify requirements for hydraulic brake systems and brake hoses, respectively. Section 108 of the Safety Act provides:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicl e safety standard.

The purpose of the BRAKE LOCKER is to prevent the theft of parked vehicles by locking the brakes while theft is attempted. The product also is designed to enable regular brake usage while being driven by the car owner or another authorized driver.

The BRAKE LOCKER is installed in the engine compartment on the brake fluid line between the brakes and the brake pump. A controlled hydraulic tap enables two positions:

Position A: free passage of brake fluid from pump to brakes and back again.Position B: free passage of brake fluid from pump to brakes, and blockage of the passage in the other direction using a check valve.

Position B causes the vehicle to be stopped and locked, for 15-20 minutes after the brake is pressed.

The BRAKE LOCKER is designed to be controlled by an electronic coded transmitter. When preparing to move the car and activating the transmitter, the code will be recognized and the electric motor will be activated, thus bringing the hydraulic tap to Position A described above.

Upon parking the vehicle, a press on the transmitter push button activates the motor to transfer the hydraulic tap to Position B described above, thus preventing release of the brakes, after the brakes are pressed, for 15-20 minutes.

More specifically, the BRAKE LOCKER operates as follows:

1. The system is activated and a control light goes on in the driver's compartment.

2. Upon pressing the portable transmitter, the control light starts blinking, the electronic motor then turns the hydraulic tap to Position A which enables the brake fluid to pass freely in both directions, and the control light then turns off.

3. Upon turning the car ignition switch on, the hydraulic tap remains in Position A and the system is prevented from being activated.

4. Upon turning the car ignition switch off and then pressing the portable transmitter, the control light starts blinking, the electronic motor then turns the hydraulic tap to the Position B "active" position so that every press on the brake pedal ca uses the brakes to be locked, and the control light will be on.

If you need further information or if a meeting with representatives of Maatzorit would be helpful to you in confirming our interpretation, please call me. I look forward to receiving your response to our request at your earliest convenience.

Thank you for your consideration in this matter.

ID: aiam0761

Dear Mr. Waldman: This is in reply to your letter of June 13, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to recreational vehicles. You ask, under paragraph S4.1 of the standard, whether materials not designed to absorb energy on contact by occupants must conform to the standard, and list materials and components which you believe might be within this classification.; Except in the case of the components specifically enumerated in S4.1 components that are designed not to absorb energy on contact by occupants are not subject to the standard. Enumerated components must conform to the standard regardless of whether they are energy-absorbing.; With respect to the materials which you list, whether or not they mus meet the standard depends upon whether they are used in the manufacture of any of the components listed in S4.1, either as surface materials, underlying materials, or padding and cushioning materials. In some cases, consequently, insulating materials such as those you list could fall within the materials that should be tested. In each case the manufacturer must determine whether the material is part of the listed component.; With reference to the components you list, open cabinets and cabine tops would be considered under S4.1 to be compartment shelves and toilets would be considered to be seat backs and seat cushions. Walls would be classified as trim panels. Lavoratories and shower doors are not within the enumerated components.; You also ask, in the case of unitized walls having a depth of 2 inche or more, whether the test should be limited to a section 1/2 inch thick. The thickness of the tested sample depends upon the portion of the component which is tested pursuant to paragraphs S4.2(a), S4.2(b), and S4.2(c). In each case, the portion of the material that is tested is cut to a 1/2 inch thickness when the portion of the material as it appears in the vehicle exceeds that thickness (S5.2.1).; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam3606

Dear Mr. Suzuki: This responds to your request for an interpretation concerning Standar No. 101, *Controls and Displays*. You asked several questions concerning informational readout displays. The answers to your questions are as follows.; >>>1. If one type of information is displayed by an electr illuminating device such as a light-emitting diode, can I define this as an IRD?<<<; The answer to this question is yes. Section S4 of Standard No. 10 defines informational readout display as 'a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where *one or more than one type of information* or message may be displayed.' [Emphasis added.] Thus, the type of system you describe comes within Standard No. 101's definition of informational readout display. In reference to the specific wording of your question, I would note that it is the definition in the standard, rather than a particular characterization by the manufacturer, that is determinative as to whether a display is an informational readout display.; >>>2. Do you think that the description 'other electro illuminatin device' includes normal electric bulbs?<<<; The answer to this question is no. The requirements applicable t informational readout displays are an exception to the usual requirements for displays, which ordinarily use normal electric bulbs. The preamble to the final rule establishing the requirements of the present Standard No. 101 explained that the reason for the exception was to 'permit the continued development of informational readout displays.' 43 FR 27541, June 26, 1978. This was necessary since current technology does not enable manufacturers to produce informational readout displays which can exhibit symbols (as opposed to words) or certain colors. Thus, while section S5.2.3 of Standard No. 101 makes the use of certain symbols and colors mandatory for traditional displays, the use of symbols and colors is optional for informational readout displays.; If 'other electro illuminating device' was interpreted to includ normal electric bulbs, traditional displays would come within the definition of informational readout display. Such an interpretation would render meaningless Standard No. 101's requirements for the mandatory use of certain symbols and colors for displays. It is thus clear that the term 'other electro illuminating device' does not include normal electric bulbs. Rather, the term was included within the definition of informational readout display, along with light-emitting diodes and liquid crystals, to avoid preventing the use of new electronic technology other than light-emitting diodes and liquid crystals.; Your third and fourth questions both contemplate that the answer t your second question is yes, rather than no. In reference to your question as to why the agency amended Standard No. 101 to permit the use of green as an alternative to blue or blue-green for the headlamp high beam telltale, the reason is that the agency does not interpret the standard's definition of informational readout display to include a mere colored light using light-emitting diode technology. To be an informational readout display, it must include information in the form of words or symbols. Since such a colored light is not an informational readout display, it must meet the color requirements of Standard No. 101. On February 1, 1982, the agency published a notice in the *Federal Register* (47 FR 4541) which proposed, among other things, an interpretive amendment to the definition of informational readout display to make that point clear. We have enclosed a copy of that notice for your convenience.; Your fourth question suggests that the definition of informationa readout display should be interpreted to include only displays providing more than one type of information. As explained in the answer to your first question, such an interpretation would be inconsistent with the wording of the standard's definition of informational readout display. The agency recognizes, however, that it is likely that most if not all informational readout displays will include more than one type of information, though it is possible that some manufacturers might use LED or similar technology for displays providing only one type. In any event, the agency is not aware of a need to revise the standard's requirements to exclude displays presenting only one type of information from the definition of informational readout display.; >>>5. According to the current regulation, is it possible to integrat telltales with other instrument displays in an informational readout display?<<<; The light intensity requirements of Standard No. 101 currently preven informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section specifies that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; We would note, however, that the notice of proposed rulemaking referre to above proposes an amendment to Standard No. 101 that would permit informational readout displays to be used as telltales. The agency is in the process of analyzing the comments received in response to that notice.; Our answer to your fifth question also covers your sixth question. hope this fully responds to your inquiry.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3110

Dear Mr. Reeves: This is in response to your letter of July 24 and your telephon conversation with Ms. Debra Weiner of my office in which you inquired about the Federal law applicable to the manufacture and use of auxiliary fuel tanks. You indicated that your client will be in the business of manufacturing auxiliary fuel tanks for use in passenger vehicles and on farm equipment. Most of the tanks will apparently be designed for mounting on the vehicles without connection to the vehicle fuel system, although some will be built with some connections.; Below is a discussion of questions numbered 1 and 6 in your letter, a well as a general discussion of the law applicable to the installation of both types of auxiliary tanks. Following is a brief discussion of the questions numbered 2-5 in your letter.; The National Traffic and Motor Vehicle Safety Act, as amended 1974 (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable either to entire motor vehicles or to equipment for installation in motor vehicles. Agricultural equipment is not encompassed by the term 'motor vehicle' because Congress clearly did not intend that such equipment be within the coverage of the Act. Therefore, none of the Federal motor vehicle safety standards are applicable to farm equipment and the rest of this letter will be concerned only with passenger vehicles.; Safety Standard No. 301-75, *Fuel System Integrity*, is a vehicl standard which applies to certain vehicles, including passenger cars, that use fuel with a boiling point above 32 degrees F. The standard applies to completed vehicles rather than to fuel tanks or other fuel system components and thus is inapplicable to the manufacture of auxiliary fuel tanks.; Despite the inapplicability of Safety Standard No. 301-75 to thei manufacture, auxiliary fuel tanks of either type you have mentioned must be designed and manufactured for safety. As a manufacturer of auxiliary fuel tanks, your client would be subject to the defects responsibility provisions of the Act (section 151 *et seq*). Upon discovery of a safety-related defect by the Secretary of Transportation, the NHTSA Administrator, or the manufacturer himself, your client, as a manufacturer, would be required to notify vehicle owners, purchasers, and dealers and remedy the defect.; A person who installs an auxiliary fuel tank in a new vehicle prior t its first purchase in good faith for purposes other than resale would be a vehicle alterer under NHTSA regulations if that person modified the vehicle during the installation. As an alterer, your client would be required by 49 CFR 567.7 to affix an additional label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Should a noncompliance or safety-related defect be discovered in such a vehicle, as a result of the modification, your client would be responsible for notifying vehicle owners and remedying the noncompliance or defect.; If your client connects auxiliary gasoline tanks to used passenge vehicles, he or she would not be required to attach an alterer's label. However, section 108(a)(2)(A) of the Act would apply. Section 108(a)(2)(A) provides in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . .<<<; Thus, if your client added an auxiliary tank of either type mentione in your letter to a used passenger vehicle manufactured in accordance with Safety Standard No. 301- 75 and other standards, and in the process knowingly rendered inoperative the compliance of the fuel system or other systems, he or she would have violated section 108(a)(2)(A).; For example, if your client mounted a tank on the exterior of vehicle, without connection to the fuel system, and one of the mounting bolts caused the existing fuel system to leak in an amount in excess of that permitted by Safety Standard no. 301-75, he would be in violation of section 108(a)(2)(A). Depending upon the way in which he attached the tank to the vehicle or to its fuel system your client could also violate sections 108(a)(2)(A) with respect to other safety standards including, but not limited to, the Bumper Standard (49 CFR 581), and Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; >>>Questions 2, 3, and 4.<<< According to the Federal Highway Administration which administers th Federal Motor Carrier Safety Regulations, they apply only to motor carriers and not to passenger vehicles that are not involved in interstate commerce. If you have further questions you might wish to contact the Federal Highway Administration directly.; >>>Question 5. Do 49 C.F.R. 171 *et seq*. which regulate th transportation of certain hazardous materials apply to the private carrying of such materials on passenger vehicles or farm equipment?<<<; These regulations are administered by the Research and Special Program Administration, which informs me that the Federal regulations applying to hazardous materials concern the transportation of hazardous materials in commerce. Thus far, the regulations have not been applied to the private carrying of hazardous materials, such as gasoline, in a passenger vehicle or farm machine. If you have further questions you might wish to contact the Research and Special Programs Administration.; In conclusion, please note that, in general, the National Highwa Traffic Safety Administration discourages the use of auxiliary fuel tanks of any kind because of the grave dangers of fire and explosion posed by their improper manufacture or installation. In the near future this agency will be making a press release warning consumers of these hazards and discouraging them from using auxiliary fuel tanks.; I hope that you will find this response helpful and that you have no been inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel

ID: nht81-2.48

DATE: 07/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: CSMPCO Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 3, 1981, providing additional information about the "Downshift Warning System Kit."

After reviewing this information and the points you make concerning Federal Motor Vehicle Safety Standard No. 108, we wish to point out that the pertinent provisions of this standard are S4.1.3 and S4.5.4. For your information, a copy of Standard 108 is enclosed.

You will note that S4.1.3 provides that: "No additional lamp, reflective device or other motor vehicle equipment shall be installed that impairs the effectiveness of lighting equipment required by the standard." Further, you will note that S4.5.4 provides that: "The stop lamps on each vehicle shall be activated upon application of the service brakes." This means that your system must not impair the effectiveness of the stop lamps that are original equipment on the vehicle, and that any application of the service brakes that does not activate the stop lamps would be inconsistent with Federal requirements. As we have made no formal study of your system, you will have to determine whether a vehicle on which it is installed would meet Standard No. 108.

Also enclosed for your information is a copy of the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) is interpreted to mean that the installation of your system on a used vehicle by a person other than its owner must not render inoperative in whole or in part, the stop lamp system. However, the prohibitions of the Act and the standard do not cover sale of your system as an aftermarket device nor its installation solely by the vehicle owner. Use of it is subject to State regulation.

We would also like to call your attention to the agency's study: "Field Test Evaluation of Rear Lighting Deceleration Signals - Analytical and Experimental Studies (1979)" (DOT HS 805 061). We urge that you obtain a copy of this report and consider it carefully with regard to your system. You may obtain a copy by writing to the National Technical Information Service, Springfield, Virginia 22161.

The agency has tentatively decided that a single high-mounted auxiliary stop lamp is the most effective way of preventing rear end collisions and has proposed that such be made available both as original equipment and in the aftermarket. I enclose a copy of the proposal for your consideration.

ENCLS.

CSMPCO CORPORATION

March 3, 1981

Frank Berndt, Chief Counsel Office of Chief Counsel, NOA-30 National Highway Traffic Safety Administration

Dear Mr. Berndt:

Compliance status of the "Chicoine Downshift Warning System Kit" with Federal Motor Vehicle Safety Standards Nos. 105, 108 and 121.

In your letter of November 14, 1980 you informed me:

* Your review of standard Nos. 105 and 121 show that installation of the kit on a vehicle would not render it noncompliant with them.

* I regard to the lighting standard No. 108, you have several questions for me to answer.

But first, I wish to inform you that I have added a "Conditioned Availability" ancillary system, to the basic kit (return samples). It is a permissive concept introduced to guard against the main system's abuser by its user(s), whether the attempt(s) is inadvertently or maliciously perpetrated.

If you will, please carry the evaluation of compliance to the lighting standard No. 108, using my up-graded system.

I have two versions to present of the ancillary system for the compliance evaluation:

First version: Vacuum Control/engine intake manifold's high vacuum condition triggers, a normally openned, permissive switch's closing. The switch is wired in series with the gear shift knob switch, the closing of both switches is required for the activation of the brake lights.

A vacuum delay valve and a vacuum control valve are added to the ancillary system, to give it a time delay effect that will reduce the system sensitivity to the intake manifold vacuum fast variances. This way an operator can upshift without incurring activation risks of his vehicle brakelights.

1) Delay Valve

A delay valve is fitted in the vacuum line between/near the permissive vacuum-operated switch and the present vacuum control valve. The delay valve is an air flow (vacuum) restrictor, it allows unrestricted flow of air one way and impeded flow the other way. It is necessitated for protection continuity in upshift operation.

2) Present vacuum control valve

The preset control valve is vacuum operated and is fitted in the vacuum line between/near the delay valve and the intake manifold. The preset vacuum control valve closes when the vacuum drops by 5" hg. below the triggering vacuum setting of the permissive vacuum-operated switch. It is necessitated for protection continuity in upshift operation.

Second version: Electronic control/the control device's logic reads the vehicle's deceleration rate and compares it to the manufacturer selected rates (i.e.: 1.5 mph/sec. is acceptable). And as long as the vehicle deceleration rate matches or exceeds the device's set rate, the control device enters and remains into an available operative mode. With the electronic control device in an available operative mode the vehicle's operator can then activate his vehicle's brakelights by using the gearshift switch.

Hall Effect Devices or Wire Coils are used with magnets to generate signals of vehicle velocity to the electronic control device. The takeoffs are from the vehicle's drive shaft or the vehicle speedomaster cable.

A power transistor that is built-in with the electronic control device, is used instead of the electrical-mechanical relay found in the basic kit.

To your first question: "We would like to know if your system prevents the turn signal lamps from flashing, in lamps combining stoplamp and turn signal lamps."

The answer is no. My system will not prevent the turn signal lamps from flashing in lamps combining stoplamps and turn signal lamps.

First reason) The brake switch is not a controlling component for the turn signal lamps flashing operation(s).

Second reason) The kit's relay contact are wired in parallel with the brake pedal stoplamps switch's tabs in other words, the existing switch is simply wirejumped and the kit's relay switch is substituted for the existing brake switch.

I have a '78 Fiesta-Sport Model and it has the lamps combining stoplamps and turn signal lamps that your question refers to. Closing of the brake pedal switch does not prevent the turn signal lamps from flashing, nor does the closing to the kit relays contact prevent the turn signal lamps from flashing. I carried the experience in my garage.

Reply to your second question and closing request: "We would like clarification whether the system activates the stop lamps by pushing the button alone or whether actual motion of the gear shift lever is also required. If the former, we would appreciate your views on possible abuses) of the system, . . . . "

Your second question and closing request convey a message of concern for abuse(s) of the system. That message has influenced my decision to supplement my basic kit with the conditioned availability ancillary system, both versions are automated, beyond operator's control, and work on a permissive concept basis to keep in check main system's abuses.

The content in your second question is a good example of conditioned availability -- the motion of the shift lever be reflected as a condition to fulfill for the system operativeness. But I have not selected as a requirement the motion of the shift lever for the system operativeness.

I have given consideration to the following points:

1) The gear selection(s) for an upshift or a downshift in vehicle(s) equipped with a manual transmission is left to the operator's discretion and vehicle's demand(s).

2) The traffic flow pattern(s) does very i.e.: A traffic flow pattern may dictate a downshift:

* for an acceleration of the vehicle

* for a deceleration of the vehicle

3) The cost of retrofitting of the vehicles already on the roads.

4) The selected permissive ancillary systems' operations:

* are to be fully automated

* are to be controlled by inputs that are relating to the vehicle modal status of acceleration and deceleration.

* in case of component(s) failure, the system is to become inoperative, the fail safe concept.

5) The activation of the downshift warning system kit is to remain a manual, conscious operation by the vehicle operator.

6) The language of the vehicles' stoplamps: To the non-lead driver, the following message have become universal standards, for the vehicles moving on relatively flat grade.

1. Stoplights OFF - Brakes OFF - STOP NOT IN Progress

2. Stoplights ON - Brakes ON - STOP IN Progress

*3. Stoplights OFF - Brakes ON - STOP IN Progress

**4. Stoplights OFF - Brakes OFF - STOP IN Progress

* The message applies in cases where the stoplamps system of the lead vehicle is defective (i.e.: burnt stoplamps).

** The message applies in cases where the lead vehicle operator uses the engine brake (downshifts) to come to a stop or a slowdown. I refer to this message as "The Burnt Stoplights Syndrome."

Note: Operating a vehicle that has its stoplamps system out of order (i.e.: burnt stoplamps) is inconsiderate of other people's safety and is incomsiderate of one's (operator) own safety as well. The same can be said for the operator(s) that downshift to a stop. I address this "The Burnt Stoplamps Syndrome." The use of the device can help keep in check "The Burnt Stoplamps Syndrome." The device restores safety to the operator(s) that uses the downshift method to stop/slowdown his vehicle. The following driver(s) will share same.

7) The device is not to impair the integrity and effectiveness of lighting equipment that the standard requires. The device is to enhance the integrity and effectiveness of lighting equipment that the standard requires.

Downshifting makes use of engine braking energy instead of letting it be wasted. In a world that is energy short, let's make it safe to use that stopping method.

I trust that I have satisfactorily answered your questions. Enclosed is a flow-sheet layout copy of the kit's components and wiring, first version adaptation.

Gustave J. Chicoine, President CSMPCO Corporation ENC.

(Graphics omitted)

WIRING DIAGRAM

ID: aiam1424

Dear Mr. McIntosh: This is in reply to your letter of February 19, 1974, forwarding to u for approval a draft notification letter regarding the Checker front seat adjuster (CIR-727).; The one remaining problem we have with your letter is in the secon paragraph. Because Checker is a manufacturer of motor vehicles, the appropriate determination by Checker pursuant to S 577.4(b)(1) is that the defect exists in the motor vehicles in question. Your second sentence should be changed, and may be changed to read, 'The Checker Motors Corporation has determined that a defect which relates to motor vehicle safety exists in some 1972 model Checker vehicles manufactured from December 9, 1971, through April 5, 1972, and results from improperly installed front seat adjuster assemblies.'; We have decided to accept notification letters in which the referenc to 'some' vehicles (S 577.4(b)(2)) is placed in the sentence required by S 577.4(b)(1).; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: aiam2748

Dear Mr. Milby: This responds to your January 5, 1978, letter asking whether the join connecting the front roof cap to the windshield header is considered a joint subject to the requirements of Standard No. 221, *School Bus Body Joint Strength*.; Standard No. 221 applies only to joints connecting body components t body panels in a bus body. Bus body is defined as 'the portion of a bus that encloses the bus's occupant space, exclusive of the bumpers, the chassis frame, and any structure forward of the forwardmost point of the windshield mounting.' Any joint falling outside the area prescribed for the definition of bus body is not considered a joint subject to the standard.; If the joint to which you refer is forward of the *forwardmost* poin of the windshield mounting, it is not subject to the requirements of the standard. The location of this joint, however, is not clear from your letter. The second paragraph of your letter indicates that the lower portion of the windshield glass extends forward of the referenced joint. If the lower portion of the windshield mounting as well as the glass is forward of the joint in question then that joint lies within the area defined as the 'bus body' and is subject to the requirements of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: nht81-3.4

DATE: 08/04/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Jean's Portable Highchair & Car Seat

TITLE: FMVSS INTERPRETATION

TEXT: Your letter to Mr. Vladislav Radovich was forwarded to my office for a reply. You wrote concerning information on Federal regulations applicable to child restraint systems. In particular, you were seeking agency approval for the child restraint system you propose to market.

Manufacturers of items of motor vehicle equipment, such as child restraints, are regulated by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.), a copy of which is enclosed. The Act does not authorize the agency to approve products. Section 114 of the Act requires "self-certification" by manufacturers that their product complies with all applicable Federal motor vehicle safety standards.

In the case of your product, the applicable standard is No. 213, Child Restraint Systems. The new version of that standard, which went into effect on January 1, 1981, requires manufacturers to certify that their child restraint system can meet the dynamic test and other requirements of the standard. I have enclosed a copy of Standard No. 213 for your reference.

As you requested, I am returning the pictures enclosed with your letter. If you have any further questions, please let me know.

ENCLS.

July 15, 1981

Vladislav Radovich Office of Crashworthiness National Highway Traffic Safety Admin.

Dear Mr. Radovich:

We are enclosing copies of two of the letters we have sent out to get our car seat approved.

It was suggested that we write to you for your approval and to also get a copy of your Standard 213 Child Restraint Systems.

Statement of Facts:

1. This baby seat made of tough coated nylon is also anchored to metal car seat by one inch webbing and is absolutely safe.

2. With the use of car seat belts this car seat becomes the safest car seat available today and will protect the child just as securely as the adults are protected. With the use of "car seat belts" it will stand any collision teast.

3. Jean's Car Seat can be used in the front seat and is as safe as the back seat as long as "car seat belts" are used. (See brochure) This is a must with Jean's Portable "Car Seat" just as it is with other restraint units.

Picture #1 - I have sent this picture to show the 1 1/2" webbing anchor strap - the black one extending below the baby seat. This is to be used in cars in the back seat, that do not have shoulder straps. The lap seat belt must be threaded through the anchor strap which can be lengthened or shortened as needed and this keeps the top of the seat from going forward in a collision and is extra protection as the lap seat belt must go over the chair as is shown in the brochure under "Car Seat".

Picture #3 - shows shoulder seat belts in rear seat.

We sincerely hope you will advise us of your ideas and that you will approve our car seat. Please return pictures.

Willis. R. Dunkley Jean's Portable High Chair & Baby Products

June 4, 1981

Karl C. Clark Office of Vehicle Standards & Restraints

Dear Sir,

Your Mr. Robert Ingersol of the Safety Department at Salt Lake City, Utah, has referred your name to me as one who can advise me concerning the car seat and the safety factors involved when it is used as a restraining unit. The item is called "4 in one" Jean's Portable Highchair because it is not only a portable highchair but can be used as a car seat and a back pack and a cuddly coo.

You can see by the pictures enclosed it is an item we hope will assist many families in handling their young children. Our daughter, Jean, designed the unit and we added the car seat which if used properly with car seat belts will be perfectly safe. While it does not have the appearance of being as comfortable as many car seats on the market it does hold the child firm and yet is very comfortable and as safe as any adult in the car who uses "safety belts."

We need your advice in the matter and your suggestions when used as a "child restraintment". As you will note by the pictures, the car seat with the portable highchair attached can be set on a chair at the table instead of fastening it to the regular chair or a bench in the restaurant etc. It is also a very good back pack for babies and a cuddly coo. Thus it is a very practical item and will take care of the entire baby needs. We do not sell it as a plush item but a practical and convenient unit most young families can afford. As you will note the car seat folds up which makes it convenient as it folds into a small space when not in use. We have also enclosed most of the metal parts in a rubber covering which makes it very practical when sitting on car seats and furniture. We feel it has a marketable use for families and can be approved as a very safe car restraintment for children from 3 months until 2 years.

We will certainly appreciate an immediate reply on your judgement and ideas.

Thank you. Please return the pictures. . .

Willis R. Dunkley Jean's Portable Highchair & Car Seat

July 1, 1980

Michael A. Brown Consumer Product Safety Commission

Dear Mr. Brown:

Last summer my daughter Jean Brown was home from Germany for two months, she and her husband, a dentist, are spending three years in Viesbaden, Germany, to repay Uncle Sam for an Air Force scholarship they used for schooling in Washington. While home for two months she devised a portable high chair (see picture) later we turned it into a 3 in 1 - a portable high chair, a baby back-pack, and a cuddly coo. It seems safe and properly made for these items and people who use it love it. The patent is pending. Still further we have made a car seat from steel tubing which supports the portable high chair and which when fastened to the car seat belt provides a car seat which is comfortable, easy to handle, safe and light in weight and when not in use foldsup and it can be stored in small areas or placed in trunk of a car easily and handily. In addition when unstrapped from the seat belt it can be carried with the baby to a restaurant or other chairs and provides an opportunity for the baby to sit at the table with the parents. It can also be used on church pews or any seat or bench for that matter.

We have a Distributing Company in Phoenix as well as a lot of local stores who will purchase the 3 in 1 as well as the 4 in 1 units if it is a satisfactory consumer product and has your approval.

My daughter and her husband have two more years of school in Philadelphia for him to become an Orthodonist and they need all the help possible and for this reason, as their father, I am attempting to assist them with the "Jean's Portable High Chair."

From the pictures you can see our plans. We may have to change some buckles and the positive fasteners on the car seat need some refining etc. but the patent attorney has really encouraged us. Under seperate cover we are shipping it for your testing and approval. We need your guidance. Insurance Companies have already given us liability insurance and we have companies who will produce the portable high chair and a second manufacturing company who will tool up and produce the car seat on a mass production basis. The Phoenix distributing company now works with chain stores such as Skaggs, J.C. Penneys, etc and our hopes are already very high so we hope it meets with your approval. Jean's Portable High Chairx And Baby Products Inc., Willis R. Dunkley

Enclosure Omitted.