Interpretation ID: nht91-6.27

DATE: October 16, 1991

FROM: S. Suzuki -- Managing Director, Suzusho Trading Co.

TO: Director, Office of Public and Consumer Affairs, NHTSA

TITLE: Ref. No. ST-9015/91

ATTACHMT: Attached to letter dated 1/31/92 from Paul Jackson Rice to S. Suzuki (A39; Std. 108)

TEXT:

RE: NEW TYPE OF HIGH-MOUNTED STOP & FLASHER LAMPS.

We have already learned the Merit of High Mounted Stop Lamp, therefore, the late models are coming with it from the factory, then we improved this High-Mounted Stop Lamp which is attached Flasher Lamps to give driver's informations to behind drivers quickly.

We introduced our High-Mounted Stop & Flahser Lamps to CHRYSLER CORPORATION then, Mr. Michael M. Fischer introduced us to contact to you about rear lighting because rear lighting on highway vehicles is regulated by Federal Motor Vehicle Safety Standards administered by NHTSA.

We made some hand-made samples and did the market research, then we could have so much requests to introduce. Everybody said that it was simple but it will convey driver's informations to behind drivers and help us not to be involved crash.

RE: MERITS FOR HIGH-MOUNTED STOP & FLASHER LAMPS

1). If drivers use it and stepped on brake pedal, the Normal Brake Lamps and High-Mounted Stop Lamp will be put on, in case, the behind driver's eye will watch High-Mounted Stop Lamp more than Normal Brake Lamps becuase it is on the eye-line. Therefore, the Flasher Lamps should be together with Stop Lamp not to make any delayed. 2). If we use our High-Mounted Stop & Flasher Lamp, the Normal Stop and Flasher Lamps will work normaly which means working together with. It will work as assistant Flasher Lamps. 3). From this reason, if drivers use our High-Mounted Stop & Flasher lamps, they can see Flasher Lamps easily without moving their eyes from High-Mounted Stop Lamp to the Normal Flasher Lamp. Our "Safety Shot" will give driver's informations of STOPPING and CHANINGING LANE/DIRECTIONS to behind drivers quickly not to be involved crashes. 4). The Snow countries, a lot of snow on the roof, bonnet, trunk etc., and snow melted roads, the rear side of cars should be dirty and it will be difficult to see. All drivers will remove snow on the Front/Rear and both side of Glasses to see before they start driving. In case, if drivers use our "SAFETY SHOT" High-Mounted Stop & Flasher lamps, behind drivers will be able to see it easily and we will be able to avoid crashes etc.,

5). There is a lot of clouds of spray when we drive high speed on the Highway in the rain day, in case this clouds of spray will disturb Normal Stop and Flasher Lamps, however, the Center of Rear Glass scheild should be the ravine from the both side clouds of spray and we can see

High-Mounted Stop Lamp well, therefore, we should put Flasher Lamps together with Stop Lamp.

We think that it will be important very much to save drivers if we had an accident such as Airbag System, Door Side Beem etc., but if we can have somethings not to cause accidents or to avoid accidents, it will be much valuable for drivers. Drivers will not hesitate to pay extra expenses to save themselves but they expect these devices are not expensive.

We need High-Mounted Stop Lamp on the busy Highway. If the highway is very empty, we do not need it at all. All big cities in the world, many cars are on the road, therefore, all drivers would like to know the former driver's informations, STOPPING, CHANGING DIRECTIONS, etc., and if we can know tow or three former driver's informations, we can change our lane soon and we can avoid the trafic jam, too.

Of course, there are many differnt countries and different way of thinking and different people, therefore, everybody will not agree the above suggestions, however, if we have to reply which is more safety, to use our High-Mounted Stop & Flasher Lamp or not to use it. In case, everybody will reply, it will be more safety if the "SAFETY SHOT" is built-in rear window.

We are pleased to enclose our hand-made samples (pictures) for your study as under:

* " Safety SHOT - Type I" : L.E.D. Use.

* " Safety SHOT - Type II" : L.E.D. Use.

* " Safety SHOT - Type III" : General Electric Bulb Use.

We will produce goods and introduce them in our domestic market, therefore, is it possible to use it in the U.S.A. or not.

We are much appreciated if we can received your comments on this matters.

Thanking you for your best co-operations and looking forward to hearing from you soon, we remain, yours very truly.