Interpretation ID: nht73-1.25

DATE: DECEMBER 7, 1973

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Reservation Business Enterprise

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 16 concerning a definition of "steady burning" lamps.

Our definition of "steady" is "regular, uniform; not changed, replaced or interrupted; not fluctuating or varying widely." Stop lamps activated by the Pulsating Safety Brakelite would therefore not be "steady burning."

Thank you for your interest in highway safety.

Sincerely,

ATTACH.

November 16, 1973

E.T. Driver, Director -- Office of Operating Systems, Motor vehicle Programs, U.S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Driver;

Over a year ago, I wrote you concerning our "Pulsating safety brakelite". Recently we have developed a legal question concerning our product and Federal Motor Vehicle Safety Stanlanl no. 108. 108 states that the brakelite must be steady burning. Our device does not over turn the bulb out but only changes it's brilliance in a pulsating manner.

Our question is; does "steady burning" mean that the bulb must always be on, and therefore our product falls within that definition or does it require it to burn at a steady intensity which would make our product fall outside the definition.

We are very eager to get this clarified.

Sincerly

Mel Aanerud, Manager -- RESERVATION BUSINESS ENTERPRISE