Interpretation ID: 1983-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 12/08/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: TWI Inc. -- Bill Perzinsky, President

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Capt. Perzinsky:

This is in reply to Your letter of October 14, 1983, to Mr. Vinson of my staff regarding your F-S-700 A flasher. The device is essentially a slender bar of lights mounted on the rear panel shelf of a passenger car. The left and right sides blink to indicate turns in the appropriate direction. The entire bar lights up when the brake pedal is applied. You ask for our "approval" of this device.

The Federal motor vehicle safety standard on lighting forbids the installation of motor vehicle equipment that impairs the effectiveness of lighting equipment required by the standard. Stop lamps are required by the standard. They must be red. They must go on when the brake pedal is applied. The stop signal put out by the F-S-700 flasher is amber, not red. Therefore, an amber signal coming on at the same time as a red one would impair the effectiveness of the red stop lamp by creating confusion.

The Federal lighting standard allows either amber or red turn signal lamps. There is obviously a potential for confusion if your amber light device is on a vehicle whose turn signals are red. But an even greater problem with interior-mounted lamps, whatever their color, is the reflection that they cause in the rear glass, particularly when it's raining or snowing, interfering with the rear vision of the vehicle's driver.

For the reasons given above the F-S-700 A flasher causes us some concern. Further, you should investigate whether the laws of the jurisdiction where you wish to sell this device will permit its installation and use.

Sincerely,

Oct. 14th, 1983

Dear Mr. Vinson:

We are sending you a flyer of our new product. F-S-700 A 4 star flasher.Would like to know if this type of light would meet standard safety.I would like to send you a sample of this light, as you would be amazed what this light can save lot of lifes and accidents.

I have one installed in my car, every one that see me with it wants on his car. I can't sell them until I get approval from Highway Traffic Safety. Please Let me hear from you at your earlest convenient time, thank you. If you need a sample let me know.

2. Flyers enclosed

Sincerely,

Capt. Bill Perinszy President TWI INC.