Interpretation ID: aiam2010
611 Bouldin Avenue
Austin
TX 78704;
Dear Mr. McNiel: On May 12, 1975, you petitioned the National Highway Traffic Safet Administration for rulemaking to amend Standard No. 108 to provide 'A means that will hasten the illumination of a vehicles conventional stop warning lamps at any time that a 'panic' or any other exceptionally sudden stop is made, but wherein the said means will not affect the normal functioning of the vehicles lighting system at any other time.'; We have given thoughtful consideration to your petition. It appears t us that the system you prefer would indicate only that the accelerator pedal had been released suddenly, and not that a sudden or 'panic' stop was being made. In our view, a sudden release of the accelerator does not necessarily mean that a panic stop is in progress. Conversely, all sudden stops are not necessarily accompanied by a sudden release of the accelerator. In short, the presumed benefit of the system appears speculative, and no data have been submitted demonstrating that the signaling system would enhance highway safety. For these reasons your petition must be denied.; Standard No. 108 would not preclude the sale of your deceleratio warning device in the aftermarket, subject to regulation by the individual States.; We appreciate your interest in motor vehicle safety. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;