Interpretation ID: nht94-2.90

TYPE: INTERPRETATION-NHTSA

DATE: May 16, 1994

FROM: R.H. Goble -- President, R.H. Goble Enterprises, inc.

TO: Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 6/29/94 from John Womack to R.H. Goble (A42; STD 108; VSA 108(a)(2)(a))

TEXT: R.H. Goble Enterprises has developed a new lighting system to be added to motor vehicles. We are soliciting input from you as to the current rules and regulations and how they may apply to this new system. Specifically, can brake lights appear over the wheels and in the front of a vehicle?

Traffic and highway safety is a critical factor in our society. New ideas have evolved over the years to improve highway safety. The most recent innovation is the introduction of the eye-level rear view brake light. Rear-end collisions have been re duced by fifty two percent as a result.

This new concept worked because it introduced a change which was immediately apparent to drivers following a vehicle. We believe this same principle should be applied to the front and sides of a vehicle. The, other drivers could discern the braking intent of the operator from any direction. This is especially true in congested areas where one must watch for vehicles entering from side streets and on coming traffic. This can be accomplished by simply wiring the brake lights to the directional ligh ts with an ordinary bridging connector.

NOTE: When wiring the brake lights to the front directional and side marker lights the brake lights are over ridden by the directional lights.

Also, when the brake lights are applied both sides light up, with the directional light on one side flashing.

Brake lights will not interfere with the directional lights or hazard lights functions.

As seen in the enclosed packet we are introducing a further safety enhancement for vehicles. The Wheel Well lighting system provides indication of the drivers intent when viewing the vehicle

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from any direction. This takes more of the guess work out of being a defensive driver.

The obvious awareness of another vehicle and the intentions of its operator are the keys to avoiding a collision. The Wheel Well lighting system provides complete illumination around the vehicle, with all light indications or signals being visible fr om any direction. Therefore, we can provide the same safety advantages for all drivers, not just those approaching from the rear. In addition, the reflection of the Wheel Well lights off of the wheels will draw attention to the vehicle even more.

This is not just an idea. Our lighting system is already being used on a few vehicles locally. Four hundred lights have been produced to perform a marketing trial and provide consumer feedback.

The Wheel Well lights utilize standard lights, bulbs, and wiring. They are inexpensive and simple to install. We believe this new patent pending product will do even more to revolutionize highway safety than even the eye-level rear view brake light.

Please understand that these new lights are standard vehicle lights already manufactured by Peterson Manufacturing. Our system merely provides for placement of the newly designed lights above the wheels. They are directly wired into the vehicle and provide the same signaling around the vehicle as can be seen from the rear of any standard vehicle.

Please advise us as to the legality of providing this new system in existing vehicles.