Interpretation ID: nht92-2.44

DATE: 11/06/92

FROM: RICHARD HORIAN -- PRESIDENT, WOODLEAF CORP.

TO: PAUL J. RICE -- CHIEF COUNSEL, NHTSA

TITLE: SUDDEN BRAKE INDICATOR HAZARD LIGHT

ATTACHMT: ATTACHED TO LETTER DATED 12-7-92 FROM PAUL J. RICE TO RICHARD HORIAN (A40; STD. 108)

TEXT: Enclosed is an official request for proposal to allow a vehicular lighting system that warns when an emergency braking situation or other hazard is occurring. Simply, when a driver engages in hard braking, a circuit activates a separate lighting system to warn other drivers to pay special attention to a potentially hazardous situation.

The Sudden Brake Indicator Hazard Light is different from other similar systems proposed over the years with the following unique advantages:

(A) An electronic pressure switch is used within the brake pedal assembly. No hydraulic pressure switch is mounted within the vehicle's hydraulic brake lines. If the electric pressure switch fails for any reason, all existing braking and lighting systems on the vehicle remain unaffected.

(B) Increased foot pressure being applied during hazard braking conditions is a natural ergonomic reflex. The driver does not have to divert his attention to activate a manual switch or other device.

(C) The Sudden Brake Indicator Hazard Light may be activated when the vehicle is not in motion. Most rear end collisions occur when the lead vehicle is stopped. If the stopped lead vehicle driver notices in his rear view mirror that another driver is approaching too fast, he simply has to depress his brake pedal with greater pressure to instantly activate the hazard light. No time is lost as the driver's foot is already on the brake.

(D) In emergency situations when a vehicle goes off the road and comes to a stop, the hazard light may be instantly activated by harder depression of the brake pedal. This is primarily important during night time freeway driving. Precious seconds are not lost while searching for the manually activated hazard light switch until it is turned on.

(E) Most importantly, there is no chance of drivers becoming desensitized to the Sudden Brake Indicator Hazard Light as it is rarely used. Other proposed systems were designed to be activated during all braking conditions. With these systems, either flashing or steady burning, this is tantamount to just another brake light that sooner or later would be regarded the same as existing brake light designs.

ATTACHMENT

Mr. Paul J. Rice Chief Counsel National Highway Traffic & Safety Administration 400 7TH Street, Room 5219 Washington, DC 20590

REFERENCE: SUDDEN BRAKE INDICATOR HAZARD LIGHT

Dear Mr. Rice,

Please allow a written opinion for allowance of a Sudden Brake Indicator vehicular hazard lighting system described as follows.

A separate hazard brake light system that is activated only when a predetermined threshold of pressure is reached upon physical depression of a vehicle's brake pedal. The hazard brake light system primarily consists of two components: (A) A pressure sensitive electronic switch mounted within the vehicle's brake pedal assembly that is activated only when a predetermined amount of foot pressure is applied to the brake pedal that is usually greater than those pressures applied during normal driving conditions (as an example, foot pressure application greater than 25 lbs. of force). (B) A light or light assembly that is mounted to the rear of the vehicle that when illuminated, may warn other vehicles of a sudden braking or other hazard situation.

The hazard light may be red or amber in color and steady burning or flashing as required to warn other drivers that a hazard situation may be occurring so that special driving attention should be employed.

The hazard brake light system will be mounted in one of two places. (A) The high mount stop light outer housing will be slightly expanded to contain a separate inner housing or housings with separate bulb and lens coverings from that of the high mount stop light. (B) Elsewhere on the rear of the vehicle so as not to conflict with the other lighting functions mandatory on the vehicle.

The switch, hardware, wiring, lights, lenses and housings will conform to all existing Automotive Codes of Federal Regulations. The hazard light system will be design manufactured and installed for use only on original equipment manufactured vehicles.

Sincerely,

Richard Horian

President