Interpretation ID: nht94-3.55
TYPE: INTERPRETATION-NHTSA
DATE: July 5, 1994
FROM: Lawrence Farhat -- President/CEO, Neon Riders of America, Inc.
TO: John Womack -- Acting Chief Counsel, NHTSA
TITLE: NONE
ATTACHMT: Attached to letter dated 8/9/94 from John Womack to Lawrence Farhat (VSA 108(a)(2)(A))
TEXT: Dear Mr. Womack:
My name is Lawrence Farhat, President/CEO of NEON RIDERS of America, Inc., Jacksonville, Florida. Please accept this as an official written inquiry, regarding under-carriage neon lights, which we have been manufacturing and shipping, both nationally and internationally, for approximately three years.
Unfortunately, there has been some confusion, on a state by state level, as to the acceptability and/or legality of the under-carriage neon lights. There are a very few local and state officers that have issued citations for "improper lighting." To the best of our knowledge, when fought in court, these citations have been dismissed by the judge.
We offer 10 colors in our product line: purple, pink, green, aqua, orange, tangerine, yellow, white, red and blue. It has been deemed by the State of Florida, that displaying red or blue lights, even under the vehicle and concealed, to be illegal when v isible from the front. Granted, this is a gray area of the law, since most all police and rescue vehicles have blue and red lights. However, police and rescue/emergency vehicles display their lights mounted on top of the vehicle, always flashing and ve ry visible. Our product is mounted under the vehicle, and is concealed to the point where you cannot see the neon light bulb itself. Instead, all you see is the reflection of the light onto the ground. Please see the enclosed photograph, which shows e xactly what the lights look like when installed. There are four tubes, (front, rear and both sides), giving the vehicle the appearance of floating on a cloud of light! Hopefully, you have already seen at least one vehicle with these neon lights under it . Neon light ground effects are considered an accessory to all motor vehicle (cars, trucks, vans, tractor-trailers, motorcycles, boats, ATV's, snowmobiles, and even bicycles). These lights not only serve an aesthetic value, but also, and most important ly, as a safety feature. It is obvious that these neon lights are an innocuous accessory, when installed
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correctly, under the vehicle.
The Jacksonville Sheriff's office has installed blue neon on all of the motorcycles in the department, and their reports have been very, very favorable. A contact name and phone number is available at your request. The New Orleans Police Department, as well as several other city police departments, are also interested in putting neon on their vehicles for safety purposes.
We do not feel that our product falls under the description in your Section 108. Neon is not a poisonous gas, nor can it explode . . . this is a fallacy. We consider our manufacturing process to be THE HIGHEST in the industry for quality and safety. I have enclosed a cut-away section of a tube for your inspection. This will give you an idea of how the tubes are assembled, and how well protected the neon bulb itself is. The tube fits inside a metal shield to conceal the tube from direct visual contact . The neon operates off any 12v battery system, with a transformer that produces 9000v, secondary for neon. This transformer, which is about the size of a beeper, has it's own safety factor built into each unit, causing it to automatically shut off if i t detects any problems. Every tube that we distribute is quality control tested prior to shipping.
Please inquire with your colleagues as to the validity of our existance as a Florida Corp., manufacturing and distributing these neon light ground effects within the continental United States and abroad. I am looking forward to your response. If you ha ve any questions, or you need any additional information or technical data regarding the lights, please do not hesitate to contact me at the toll-free number printed below.
Thank you in advance for your time and consideration.
LF/klp