Interpretation ID: aiam4409
Jr.
P.C.
Law Offices
RFD #8
Box 369
Union Valley Road
Mahopac
NY 10541;
Dear Mr. Milde: This is in reply to your letter of October 2, 1987, with reference t an electronic circuit that would automatically activate a vehicle's hazard warning system when the vehicle is proceeding slowly, or has stopped in the roadway. You have asked whether such a system has been proposed before, or field tested, and whether Federal Motor Vehicle Safety Standard No. 108 would permit its installation on motor vehicles.; The traffic hazard that concerns you, especially that presented by vehicle that has stopped in the roadway without activation of either brakes or hazard warning system, is one that is familiar to many motorists. However, it appears that in actuality most motorists confronted with this hazard are able to react in time to avoid a rear end collision. Accident data available to the agency indicate that crashes of this nature are relatively rare. As you know, many States require activation of the hazard warning system at speeds less than 40 mph on the Interstate system. NHTSA has not proposed a system of this nature, nor has it field tested one. The agency has participated in research with deceleration warning systems, a similar though not identical concept, and concluded that safety benefits were insufficient to propose their adoption.; We see no Federal prohibition against installation of a circuit tha would activate the hazard warning system at a predetermined low rate of speed. Equipment that is not prescribed by the lighting standard is permissible as original equipment as long as it does not impair the effectiveness of equipment that Standard No. 108 does require. And modifications of vehicles in use by persons other than the vehicle owner are permissible as long as they do not render inoperative, in whole or in part, vehicle equipment necessary for compliance with a Federal motor vehicle safety standard. Nor are we aware of any State restrictions on the use of such a system, though you should consult the American Association of Motor Vehicle Administrators for a definitive answer. Its address is 1201 Connecticut Avenue, NW, Washington, DC 20036.; Sincerely, Erika Z. Jones, Chief Counsel