Interpretation ID: aiam3811
President
LJM Associates
Inc.
22030 Lanark Street
Canoga Park
CA 91304;
Dear Mr. Mandell: This is in response to your further letter of December 15, 1983 regarding your lighting device, asking me to reconsider my views of November 22 that it offered the potential for impairment of lighting equipment required by Standard No. 108.; To recap, your device utilizes the body panel between the left an right rear lamps to emphasize braking, right and left turns, hazard flashing, and backup up. Roughly, it operates by lights (red? amber?) spreading from the center of the red translucent panel outward, in either or both directions. I concluded that the novelty of the device offered a great potential for confusion, in the stop mode, a following driver will see the steady red light of the stop lamp at the edge of the vehicle, and also the dynamic lights spreading out from the center of the red panel. You have indicated that modification of the flash rate will not be a problem, and were the light spread activation perceptually almost simultaneous with that of the stop lamp, the possibility of impairment would diminish.; I also commented that the same dynamic light spread is seen but mean to indicate something entirely different when both turn signal lamps are operating simultaneously (your system's hazard warning mode). Since all lamps are flashing, we believe that the potential for impairment is much less in this instance.; We note that you have added two further functions since last writing u about your device: displays of words in the hazard mode indicating whether road service or police aid is needed. This is an interesting concept and we regard it as a supplement to the hazard signal which would not impair its effectiveness.; In the final analysis, aftermarket equipment such as you propose t offer, which is not itself incorporated into the Federal lighting standard, is subject to the 'approval' or 'disapproval' of the various jurisdictions in which motor vehicles equipped with it are being operated. It is a mistaken impression that the Federal Government 'approves' or 'disapproves' aftermarket equipment. The National Traffic and Motor Vehicle Safety Act gives us no authority to 'approve' or 'disapprove.' We can and do, however, point out potential problems of a safety nature that may arise from use of a device that is not covered by a safety standard.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel