Interpretation ID: 22613.ztv

Mr. Paul Michelotti
PM Technology
2850 Banyan Blvd. Circle NW
Boca Raton, FL 33431

Dear Mr. Michelotti:

This is in reply to your letter of January 12, 2001, to Frank Seales, Jr., the former Chief Counsel of this agency.

You have asked whether "Federal Motor Vehicle Safety Standard No. 108 or any other federal regulation prohibit a hazard warning operating system that provides for automatic activation of vehicle hazard warning lights in an accident situation, in situations of rapid deceleration to a complete stop, or in situations of rapid deceleration in the speed of a vehicle over a short time interval?"

Tables I and III of Standard No. 108 require motor vehicles to be equipped with vehicular hazard warning signal operating units, as specified in SAE Recommended Practice J910, February 1966. Paragraph 1 of SAE J910 defines the operating unit, in part, as "a driver controlled device which causes all turn signal lamps to flash simultaneously." We interpret "driver controlled" as meaning that the hazard warning signal unit must be activated and deactivated by the driver and not by automatic means.

Sincerely,

John Womack
Acting Chief Counsel

ref:108
d.2/15/01