Interpretation ID: nht88-4.27

TYPE: INTERPRETATION-NHTSA

DATE: 12/07/88

FROM: ROBERT J. LATUS -- POSTMASTER US POST OFFICE PAW PAW, MICHIGAN

TO: NHTSA

TITLE: PRIMARY BRAKE LIGHT

ATTACHMT: ATTACHED TO LETTER DATED 03/02/89 FROM ERIKA Z. JONES -- NHTSA TO ROBERT J. LATUS, REDBOOK A33, STANDARD 108

TEXT: One of my Rural Carriers recently purchased a new 1989 Oldsmobile Ciera. She purchases a new car about every 4 years and prefers a new car over taking chances with a used one.

When she arrived at work with the new car, naturally she was proud and invited her co-workers and supervisor outside to look at it. The supervisor took the opportunity to check the lights turn signal etc. In checking it was discovered that when the 4-w ay hazard lights are activated, the only brake light is the much smaller light in the center of the trunk lid. The customary solid signal of the corner lights continue to flash instead of giving the STOP that they had in former models. When questioned, the dealer called Detroit, himself wondering why the change? and was told that this was the new federal regulation. He was also informed that any alteration of what came off of the assembly line was in violation of this new regulation.

I have visited many car lots and found that the "Big 3" auto makers have the same problem on their larger models. The small cars and foreign cars do not.

My question is, who changed the regulation and why? My safety and yours are at stake. Many delivery vehicles use these lights in fog, snow or rain, and their STOP is now hidden under mud, snow or a broken wire.

I have found it to be the opinion of the dealers that I have talked to that the reasoning must have been economics. Perhaps a savings of 60~ per car is more important than the safety of the delivery person or the person that is likely to run into them.

Outside warning devise on the top of these cars have proven to be less effective because of the elements. Lights that are permanently installed - and not on a extension cord as the center light brake light is in some models are much more dependable.

The center light, be it on the inside where melting snow will obscure it completely when the heating coil is activated or the outside light on the extreme rear of the trunk lid under a trim vane where it will accumulate a "back wash" of mud or snow are n ot adequate.

I have been in contact with Mr. Burl Ghastin, Michigan State Police Trafic Safety Division; Les Sokolowski, The National Safety Council, Chicago; and Postal Inspector Jerry Rosenthal in Detroit and they all feel that an explanation from your agency shoul d be sought.

In the interest of Safety, I am