Interpretation ID: 1983-3.23

TYPE: INTERPRETATION-NHTSA

DATE: 11/22/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: LJM Associates Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOV 22 1983

Mr. Lee Jay Mandell President, LJH Associates. Inc. 22030 Lanark Street Canoga Park, California 91034

Dear Mr. Mandell:

This is in response to your letter of October 19, 1983, discussing a lighting product that you have developed and asking for "the approval of the DOT or at least to insure that no active disapproval would be forthcoming.

Your device utilizes the body panel between the left and right rear lights to emphasize braking, right and left turns, hazard flashing, and backing up. Roughly, your devise operates by lights spreading from the center of the panel outward, in either or both directions.

We think that there is a great potential for confusion that this devise could create since it is so unlike anything seen before on a motor vehicle. In the stopping mode the driver following will see the steady light of the stop lamp at the edge of the vehicle, but also the dynamic lights of your devise spreading out from the center. The same dynamic light spread is seen but is meant to indicate something entirely different when both turn signal lamps are operating simultaneously in the hazard warning mode. Thus, the potential for impairment of the required lighting equipment exists.

Generally, we do not favor any lights on the rear of a vehicle that are not required by the Federal lighting standard.

Sincerely,

Frank Berndt Chief Counsel

October 19, 1983

U.S. Department of Transportation National Highway Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Attn: Chief Counsel

Dear Sir:

I am president of a small consulting firm in Los Angeles that has developed a product that at worst I believe to be a decorative device and at best I believe to enhance the safety of an automobile. I hope to be raising venture capital in the near future to allow me to go into production of this device but before I do so I would Like to obtain approval of the DOT or at least to insure that no active disapproval would be forthcoming.

This device is a display integrated into the standard rear grill many production automobiles. The intention of this device is to enchance the normal rear lights on an automobile and to exist in addition to and to not impair the effectiveness but to enchance the normal operating characteristics of the existing rear lights (Motor VehicLe Safety Standard No. 108 - S4.1.3).

The major functions of this device work in conjunction with normal light functions without any additional operator intervention. Some of these functions are:

BRAKE < -> < ---> < -----> BRAKE

RIGHT TURN

LEFT TURN

EMERGENCY FLASHERS

CAUTION

REVERSE BACKING UP

Some sample photographs are enclosed to illustrate these displays. Please feel free to contact me if necessary to insure a positive disposition of this inquiry.

Sincerely,

Lee Jay Mandell President, LJM Associates, Inc.

INSERT GRAPH HERE

INSERT GRAPH HERE