Interpretation ID: nht92-6.28

DATE: May 28, 1992

FROM: Steven Rovtar -- General Manager, Blazer International Corp.

TO: Paul Jackson Rice -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/17/92 from Paul J. Rice to Steven Rovtar (A39; Std. 108)

TEXT:

Our company, Blazer International Corp., intends to introduce a new product for the vehicle towing trailer market. Our purpose in writing is to request a written ruling that this product meets current SAE/DOT guidelines.

All trailer wiring assemblies currently available require the installer to splice into the vehicle's wire harness. Blazer's new product eliminates the need for this type of hard-wiring. Our product, which is solid-state, utilizes photodetectors to read the output of the towing vehicle's stop and turn signal lamps, and in turn activate the lamps of the towed vehicle.

More specifically, these photodetectors are embedded into suction cups which are attached to the towing vehicle's stop and turn signal lamps. Our device is plugged into the cigarette lighter receptacle of the towing vehicle, and the harness of the towed vehicle is plugged into our device. When the brake or turn signals of the towing vehicle are activated, the photodetectors in our device read the light emitted from the towing vehicle lamps, and the lamps on the towed vehicle are activated via the completed circuit.

Your prompt response in issuing a written ruling with respect to this product will be appreciated. I can be reached at the number listed below should you have any questions or require any additional information.