Interpretation ID: 86-3.42

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Jacques M. Delphin, M.D.

TITLE: FMVSS INTERPRETATION

TEXT:

Jacques M. Delphin, M.D. 84 Haight Avenue Poughkeepsie, N.Y. 12603

Dear Dr. Delphin:

This is in reply to your letter of April 2, 1986, enclosing a description of your device to improve car signals, and asking about the regulations applicable to it.

According to the information that you furnished, the device "cancels turn signal indicators immediately upon the completion of a turn". The purpose of the device is to eliminate "the need for drivers to cancel the signal manually when the turn is not sharp enough to activate the standard switch". The effect of the device is "to reduce the incidence of traffic accidents due to misinterpreted turn signals".

As you know, pursuant to Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, passenger cars manufactured on or after January 1, 1973, have been required to have self-cancelling turn signal indicators. However, there are no performance requirements for the self-cancelling feature. As a general rule, motor vehicle lighting equipment not required by Standard No. 108 is permissible as original equipment provided that it does not impair the effectiveness of lighting equipment required by the standard, and as aftermarket equipment if its installation can be accomplished without crafting a noncompliance. The device as you have described it does not appear to impair the effectiveness of the turn signal operating unit, or create a noncompliance with Standard No. 108 (the requirements of SAE Standard J589 Turn Signal Operating Unit, April 1964, which is incorporated by reference). Since Standard No. 108 does not preclude its use, the question of its legality is therefore determinable under the laws of each State where it will be used.

Although there is no Federal safety standard that applies to it, the device is an item of motor vehicle equipment subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, 1411) if its manufacturer or this agency determines that it incorporates a safety related defect.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

April 2, 1986

Ms. Erika Jones, Esq. Chief Counsel National Highway Safety Administration Room 5219 407 St, S.W. Washington, D.C. 20590

Dear Ms. Jones:

I appreciate the privilege to communicate with you regarding my device to improve traffic safety.

I am enclosing a copy of the description of the product. Please advise me as to the regulations such a device will fall under.

Respectfully yours,

Jacques M. Delphin M.D.

JMD/bp

RCC-237 DEVICE TO IMPROVE CAR SIGNALS

A Poughkeepsie, New York inventor has developed an automotive accessory which monitors and controls the operation of a vehicle's turn signal equipment.

DEVICE TO IMPROVE CAR SIGNALS cancels turn signal indicators immediately upon the completion of a turn. Equipped with an electronic timer, the device automatically triggers the vehicle's standard signal release mechanism and returns the signal switch to the off position. The device is sensitive to all turns of the steering wheel, regardless of the degree of the turn. Installation of the device eliminates the need for drivers to cancel the signal manually when the turn is not sharp enough to activate the standard switch. Use of DEVICE TO IMPROVE CAR SIGNALS is designed to reduce the incidence of traffic accidents due to misinterpreted turn signals.

The original design was submitted to the Rochester Office of INVENTION MARKETING INCORPORATED, a national invention development organization for research and marketing. INVENTION MARKETING INCORPORATED is currently offering this invention for licensing to manufacturers interested in research and development.

Details May Be Obtained By Contacting: NEW PRODUCT LICENSING DEPT. INVENTION MARKETING INCORPORATED TRIANGLE BUILDING - 701 SMITHFIELD ST. PITTSBURGH, PA 15222

Note: We are unable to reveal working details of this invention, and this release does not constitute an offer for sale. This data is available only to qualified manufacturers and marketing agents on a confidential basis.