Interpretation ID: nht78-1.26

DATE: 03/02/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: H. A. Bullock

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 29, 1977, letter asking whether Standard No. 124, Accelerator Control Systems, applies to a cruise control device that you manufacture.

In Docket 69-20; Notice 3, to which you refer in your letter, the National Highway Traffic Safety Administration stated that Standard No. 124 contains no requirements for cruise controls. Therefore, the standard does not apply to them. There are no other safety standards applicable to these devices.

SINCERELY,

Dec. 29, 1977

Administration Office of the Chief Council NHTSA

Gentlemen:

I have developed a mechanical automobile cruise control which I am considering marketing as an add-on product. The attached Installation and Operating Instructions and the color photos, give you a description of the cruise control and its operation.

I have been in contact with the NHTSA office in Ft. Worth, Texas and have received a copy of Motor Vehicle Safety Standard No. 124,Accelerator Control Systems (Docket No. 69-20, Notice 3). After a review of this standard and a discussion with Mr. Robert Weltzer of that office, I was not able to obtain a determination as to whether or not this standard is applicable to my add-on cruise control. Mr. Weltzer instead suggested that I forward all the information to your office for a ruling.

I have test driven the cruise control system on my own car (Honda Accord) on several cross country trips, one of 1100 miles from Texas to Florida, and have found it works exceedingly well and presented no safety complications or compromises. As a matter of fact, my experience is that I can probably disengage my cruise control somewhat quicker than I can the electronic factory installed cruise control on my Monte Carlo because of the proximity of the cruise control knob to the driver's right hand. An added feature is that any malfunction in the operation of my mechanical cruise control device causes it not to be engaged rather than the contrary.

After reviewing the information I have provided, please advise me as to whether Standard No.124 or any other standard is applicable to my device.

Harold A. Bullock [Attachment Omitted]