Interpretation ID: nht88-3.30

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 1, 1988

FROM: W. E. BALDWIN PRESIDENT, K-R INDUSTRIES

TO: ERIKA Z. JONES -- CHIEF COUNCIL, NHTSA

ATTACHMT: MEMO DATED 11-03-88, TO W. E. BALDWIN, FROM ERIKA Z. JONES, STD. 108

TEXT: This is a follow-up of a letter sent you on August 3, 1988 which you forwarded to Mr. Finkelstein of NHTSA.

As we interpret Standard S4.1, our product meets all of the requirements except, possibly, S4.5.11(e), requiring that "all other lamps shall be wired to be steady burning. Our improvement consists of a lamp containing 5 bulbs, where each bulb is illu minated in sequential order. The time between each lamp illumination is less than 250ms, providing a steady photometric value, meeting S4.1.1.41(c). The red lens of the lamp is steadily illuminated, with the illusinated area moveing in a back and forth motion.

We feel that, since NHTSA has already tested and validated the use of a high mounted break lamp, any additional testing that would be conducted would only determine any improvement in fatal accident statistics. We are not questioning the necessity of the high mounted break lamp. We are offering what we think is a improvement on the lamp, without disturbing present NHTSA standards. In order for for us to determine if it would necessitate petitioning for a Rule change, a Administration interpretatio n of S4.5.11(e) is requested. Simply put, would Rule S4.5.11(e) cover a steadily illuminated light source that moves?

Thank you for your interest in this matter. I remain