Interpretation ID: nht92-6.49

DATE: May 19, 1992

FROM: Walter T. Jakobowski -- President, Signal Dynamics Corporation

TO: Jamie McLaughlin Fish -- Director, Intergovernmental Affairs, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/30/92 from Paul J. Rice to Walter T. Jakobowski (A39; Std. 108)

TEXT:

Last October I met with Mr. Taylor Vinson of your staff, and several other staff members of the National Highway Traffic Safety Administration. The purpose of this meeting was to introduce my company's collision avoidance system to your Agency, and to discuss the proper course of action to legally use our safety device for automotive and motorcycle safety.

By way of background, Signal Dynamics has developed and patented a Safety System designed to help prevent rear end collisions. We have demonstrated this Safety System to many of the automotive, insurance, safety institutes, congressional representatives, police and local agencies. Without exception this safety item has been well received, and they are sincerely interested in seeing further development of this system.

Our corporation research shows that this Safety System can help prevent rear-end accidents. However, we have solicited independent research firms that will conduct unbias effectiveness tests to determine the value of this Safety System. It is our intention at the conclusion of these tests to present the findings to N.H.T.S.A. for consideration an to petition for a change to the Federal Code, based on the submitted Data.

In the October meeting, Mr. Vinson's position was that we could conduct testing with fleet and privately owned vehicles, because "fleet owners" are considered as individuals and therefore have the right to modify their vehicle as desired after manufacturing. Accordingly, this then does provide relief from the Federal law, so that we may proceed with the testing.

At this time we have independent research firms that are ready to proceed with testing of our Safety System. However their legal council has requested that we obtain a written legal position from your agency, with the opinion as stated by Mr. Taylor, prior to commencement of testing.

Therefore Mr. Fish, on behalf of Signal Dynamics Corporation, I am requesting N.H.T.S.A. legal position/opinion on the after market installation of safety device on privately owned, and fleet operated vehicles, so that we may begin the immediate testing of this Safety System.

I sincerely appreciate your attention to this matter and look forward to your early response.