Interpretation ID: 21065.ztv

Mr. John Newton
Pajant UK Ltd.
8 Danesleigh Gardens
Leigh-on-Sea
Essex SS9 4NL
England

Dear Mr. Newton:

This is in reply to your fax of December 9, 1999, to Barbara Rhea of this agency, enclosing information on a "progressive brake light" system. We are providing our views as to the acceptability of the system under the Federal motor vehicle lighting laws of the United States which this agency establishes and administers.

As you describe it, "the device will consist of a single unit containing four banks of lights which would sequentially illuminate depending upon the vehicle deceleration. It is intended that the device would replace the third high mounted central brake light currently in use." Specifically, the outer lamps would illuminate each time the brake pedal is pressed. The additional lights would illuminate towards the center depending on deceleration. "If maximum deceleration were detected the entire cluster would become illuminated, with the two centre banks pulsing."

I am sorry to inform you that this device would not be permitted by our laws, either as original or replacement equipment. The device could not substitute for the center high mounted stop lamp because it does not meet performance specifications we have adopted for stop lamps including the center lamp. To cite two examples: we require all stop lamps to be activated when the brake pedal is depressed, and not sequentially. Further, the stop lamps must be steady burning, and may not pulse.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.2/29/2000