Interpretation ID: nht94-4.18

TYPE: INTERPRETATION-NHTSA

DATE: September 1, 1994 EST

FROM: Williams, Harry L. Jr. -- President And Owner, Willy Lights Inc.

TO: NHTSA-Office Of The Chief Counsel

TITLE: NONE

ATTACHMT: Attached To 10/21/94 Letter From Philip R. Recht To Harry L. Williams, Jr. (A42; STD. 108)

TEXT: I'm Harry L. Williams Jr. Inventor of WILLY LIGHTS following up on a letter I received from MR. GREG NOVAK Traffic and Safety Engr. FHWA Nevada Division. A copy of that letter is attached.

I'm writing in regards to my invention. I'm now in the process of marketing the product called WILLY LIGHTS. I feel that my product will help prevent accidents that is caused by a vehicle pulling out in front of another vehicle.

My product does not interfere with any standard safety equipment on a vehicle.

I would like to know if there still are no regulations prohibiting the use of lighted wheel rims. If not which color of lights may I use since it is on the side of the vehicle and you can not see the product from the front or rear of the vehicle.

If you have any questions feel free to contact me at the above number.

Thank you for your time.

BACKGROUND INFORMATION FROM THE DOT IN MINUTE - MEMO FORM:

SUBJECT REQUEST FOR TECHNICAL ASSISTANCE

TO R J Bellard

I received a telephone call from Mr. Harry Williams (795-2334) requesting my assistance in the development of his invention to install lights on the wheel rims of vehicles. He was interested in learning about Federal regulations on such a device. I did not get further details but referred him to NHTSA in San Francisco. He called again after speaking to NHTSA there and on the Auto Safety Hot-line (1-800-424-9393) in Washington, D.C., saying that they said it was an FHWA matter. I agreed to follow up to minimize the [ILLEGIBLE WORDS] runaround he was getting, even though FHWA jurisdiction is very limited on vehicle equipment matters. I got some leads from Powell Harrison with NHTSA in San Francisco, and talked to the Crash Avoidance staff in D.C.

It appears that there are no regulations prohibiting the use of lighted wheel rims. Confirmation can be given if a written request is sent to:

NHTSA - Office of the Chief Counsel 400 7th Street S.W.

Washington, D.C. 20590

The lighted wheel rims could not, however, interfere with any standard safety equipment on a vehicle. That is handled by a self-certification statement from the manufacturer to NHTSA, so it would appear prudent for the inventor to have a copy of the vehicle standards for review beforehand. Although NHTSA will not test such a device initially because of policy, funding and manpower limitations, it may eventually purchase one once it is readily available in the marketplace. Such testing is done on a routine basis to be sure no regulations are violated and the product is free of defects. If defects are found, a recall notice could be issued. The manufacturer might have to pay damages to the purchasers in extreme cases. This quick summary in my in terpretation of NHTSA procedures after speaking with Mr. Larry Cook of the NHTSA Office of Vehicle Safety Standards - Crash Avoidance Division (NRM-II). I also spoke to Bill Leasure of the NHTSA Office of Crash Avoidance Research - Heavy Vehicle Researc h Division (NRD-53) and he did not have any problems with the use of lighted wheel rims. He also did not have any funding to test the device.

I was referred, however, to the Transportation Systems Center in Cambridge, Mass. The Small Business Innovative Research Program is centered there, run by Mr. George Kouetch. I spoke to one of his assistants and found out that new devices are consid ered on an annual basis, with the next solicitation planned for February 1989. A committee reviews proposals that address identified problems, but it sounded like lighted wheel rims were outside the current list of problem areas. Funding for testing on ly those new devices recommended by the committee is available. A proposal could be sent in response to the next solicitation, or an unsolicited proposal could also be considered at the discretion of the committee. Any correspondence should be directed to:

Mr. George Kovatch

Transportation Systems Center (DTS-23)

Small Business Innovative Research Program

Cambridge, Mass 02412

Telephone (617) 494-2051

My general impression is that a considerable amount of preparatory work is required to get an invention to the general public. The cost of lighted wheel rims may make the idea hard to sell when there may not be that much of a problem with vehicle vis ibility (reflectors and sidelights are standard equipment on most vehicles). A cheaper alternative might be to provide retroreflective sheeting on the wheel rims or body side molding. A similar proposal is being considered for truck trailers but receiv ing resistance due to the added initial and maintenance cost involved. Lighted wheel rims may have application as an after-market device for enthusiasts to install as an option. As mentioned previously, it does not appear that there is a NHTSA regulati on prohibiting it.

I would recommend Mr. Harry Williams write to NHTSA to get written confirmation of that and obtain a copy of the associated vehicle safety regulations at the same time. He could review them and certify his device to be acceptable if it does not inter fere with any existing safety requirements. I will send him a copy of this minute memo to document my effort on his behalf.

cc: Powell Harrison, NHTSA Region 9

Larry Cook, NHTSA Washington D.C.