Interpretation ID: nht95-1.9
TYPE: INTERPRETATION-NHTSA
DATE: January 4, 1995
FROM: Courtney M. Price -- Reid & Priest
TO: Philip R. Recht -- Chief Counsel, NHTSA
TITLE: Request for Interpretation/Brake Locker
ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO COURTNEY M. PRICE (REDBOOK(4)); Part 567.7; STD. 105
TEXT: On behalf of Maatzorit Ltd. ("Maatzorit"), I am writing to request confirmation of Maatzorit's interpretation of Federal Motor Vehicle Safety Standard ("FMVSS") 105, Hydraulic Brake Systems; FMVSS 106, Brake Hoses; and Section 108(a)(2)(A) of the Nationa l Traffic and Motor Vehicle Safety Act ("Safety Act") (15 U.S.C. 1397(a)(2)(A)) as they relate to the BRAKE LOCKER (U.S. Patent No. 5,375,684) which Maatzorit has developed and will market. n1 Specifically, we are requesting confirmation that installatio n of the BRAKE LOCKER is not precluded by FMVSS 105 or Section 108(a)(2)(A) of the Safety Act. We understand that the National Highway Traffic Safety Administration ("NHTSA") does not give approval of or certify devices such as the BRAKE LOCKER and that confirmation of Maatzorit's interpretation will be based upon the information provided and the circumstances described herein.
n1 FMVSS 105 and FMVSS 106 specify requirements for hydraulic brake systems and brake hoses, respectively. Section 108 of the Safety Act provides:
No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicl e safety standard.
The purpose of the BRAKE LOCKER is to prevent the theft of parked vehicles by locking the brakes while theft is attempted. The product also is designed to enable regular brake usage while being driven by the car owner or another authorized driver.
The BRAKE LOCKER is installed in the engine compartment on the brake fluid line between the brakes and the brake pump. A controlled hydraulic tap enables two positions:
Position A: free passage of brake fluid from pump to brakes and back again.Position B: free passage of brake fluid from pump to brakes, and blockage of the passage in the other direction using a check valve.
Position B causes the vehicle to be stopped and locked, for 15-20 minutes after the brake is pressed.
The BRAKE LOCKER is designed to be controlled by an electronic coded transmitter. When preparing to move the car and activating the transmitter, the code will be recognized and the electric motor will be activated, thus bringing the hydraulic tap to Position A described above.
Upon parking the vehicle, a press on the transmitter push button activates the motor to transfer the hydraulic tap to Position B described above, thus preventing release of the brakes, after the brakes are pressed, for 15-20 minutes.
More specifically, the BRAKE LOCKER operates as follows:
1. The system is activated and a control light goes on in the driver's compartment.
2. Upon pressing the portable transmitter, the control light starts blinking, the electronic motor then turns the hydraulic tap to Position A which enables the brake fluid to pass freely in both directions, and the control light then turns off.
3. Upon turning the car ignition switch on, the hydraulic tap remains in Position A and the system is prevented from being activated.
4. Upon turning the car ignition switch off and then pressing the portable transmitter, the control light starts blinking, the electronic motor then turns the hydraulic tap to the Position B "active" position so that every press on the brake pedal ca uses the brakes to be locked, and the control light will be on.
If you need further information or if a meeting with representatives of Maatzorit would be helpful to you in confirming our interpretation, please call me. I look forward to receiving your response to our request at your earliest convenience.
Thank you for your consideration in this matter.