Interpretation ID: 1983-2.37
TYPE: INTERPRETATION-NHTSA
DATE: 08/04/83
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Safety Alert Co., Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
AUG 4 1983 NOA-30
Mr. Chuck Howard President Safety Alert Co., Inc. 1667 9th Street Santa Monica, California 90404
Dear Mr. Howard:
This is in reply to your letter of June 28, 1983, occasioned by what you believe is our misconception of the way your "Safety Alert" system operates. In my letter of June 17 I stated that "Safety Alert", which was intended to flash a yellow bulb installed in the backup lamp system, would create a noncompliance with Standard No. 108 which requires backup lamps to be white in color and steady burning when in use. You now bring to our attention that your system does not alter the normal operation of the backup lamps which are steady burning when a vehicle is in reverse, even when "Safety Alert" is installed.
We understood this when we advised you that you could use "Safety Alert" through any rear lighting system which Standard No. 108 allows to flash for signalling purposes such as the hazard warning or turn signal systems. The converse of this is that "Safety Alert" cannot be used through any rear lighting system that Standard No. 108 requires to be steady-burning when in use, such as the backup lamp system, even though when used as a backup lamp it is steady burning. I am sorry this was not clear to you.
We are unaware that any foreign manufacturer is failing to comply with Standard No. 108 by installing a backup lamp system that "reflects amber" as you have told us.
Sincerely,
Frank Berndt Chief Counsel
JUNE 28TH, 1983
MR. FRANK BERNDT CHIEF COUNCIL N.H.T.S.A. 400 SEVENTH STREET, S.W. WASHINGTON, D.C. 20590
DEAR MR. BERNDT:
I AM IN RECEIPT OF YOUR LETTER DATED JUNE 17TH 1983. I WOULD LIKE TO BRING TO YOUR ATTENTION THAT OUR SYSTEM DOES NOT OPERATE AS YOU INDICATE IN PARAGRAPH TWO OF THAT LETTER.
OUR SYSTEM, SAFETY ALERT, WAS INVENTED TO SERVE THE PUBLIC AS A CAUTION LIGHT THAT WOULD FLASH FOUR TIMES IN FOUR SECONDS, INDICATING SPEED REDUCTION. ALSO IN PARAGRAPH TWO, YOU MENTION THAT THE BACK-UP LIGHTS BE STEADY BURNING IN USE. WE BELIEVE THAT SAFETY ALERT IS IN COMPLIANCE WITH THIS RULING.
SAFETY ALERT DOES NOT ALTER THE NORMAL FUNCTION OF THE BACK-UP LIGHTS. WHEN THE VEHICLE IS IN REVERSE, THE BACK-UP LAMPS ARE STEADY BURNING, NOT FLASHING.
DR. CARL CLARK, INVENTOR CONTACT, HAS ONE OF OUR DEMONSTRATION UNIT WHICH WILL SHOW THAT THE BACK-UP LIGHTS IN REVERSE ARE STEADY BURNING. THE ONLY DIFFERENCE BETWEEN OUR SYSTEM AND THE FEDERAL REGULATION IS THAT IN REVERSE OUR-BACK-UP LIGHT LAMPS HAVE A TINT OF AMBER INSTEAD OF PURE WHITE.
WE HAVE SPENT HOURS IN PARKING LOTS, LOOKING AT THE BACK-UP LIGHTS AND THEIR COLOR. THE MAJORITY OF FOREIGN CARS ARE NOW FACTORY EQUIPPED WITH BACK-UP LIGHTS THAT REFLECT AMBER WHEN IN THE REVERSE POSITION, CONSEQUENTLY IT APPEARS REASONABLE THAT THE PUBLIC AT LARGE IS ALREADY ACCUSTOMED TO THIS COLOR IN THE BACK-UP LIGHT AREA.
ALTHOUGH WE ARE PLEASED TO KNOW THAT OUR DEVICE HAS BEEN APPROVED FOR USE ON THE HAZARD LIGHTS AND TURN SIGNALS, WE STILL BELIEVE THAT THE ISSUE OF SAFETY IS BEST SERVED WHEN SAFETY ALERT IS PUT ON THE BACK-UP LIGHTS, THUS AVOIDING ANY MISUNDERSTANDING ABOUT SUDDEN STOPS.
WE SINCERELY ARE TRYING TO HELP THE REAR-END COLLISION PROBLEM AND WE KNOW THAT OUR ORIGINAL PREMISE IS BEST SUITED TO DO THIS WITHOUT CAUSING ANY MORE CONFUSION ON THE HIGHWAYS, I AM HOPING WITH ALL MY HEART YOU WILL AGAIN TAKE A FEW MOMENTS TO LOOK AT OUR DEMO KIT TO SEE THAT WHAT I AM SAYING IS SO.
MR. BERNDT, IF MY ONLY INTEREST WAS TO GET MY PRODUCT ON THE STORE SHELVES, YOUR LETTER OF JUNE 17, 1983 WOULD SUFFICE. I AM, HOWEVER, CONCERNED ABOUT THE DRIVING SAFETY OF OTHERS AND I'M NOT CONVINCED THAT INSTALLING SAFETY ALERT ON TO THE HAZARD LIGHTS AND OR THE TURN SIGNALS MIGHT NOT CREATE MORE PROBLEMS THAN THEY CURE.
NEEDLESS TO SAY, I WILL BE ANXIOUSLY AWAITING YOUR REPLY TO THIS LETTER.
VERY TRULY YOURS,
CHUCK HOWARD, PRESIDENT SAFETY ALERT CO., INC.
CH:MM CC: DR. CARL CLARK