ID: nht95-2.70

TYPE: INTERPRETATION-NHTSA

DATE: May 5, 1995

FROM: John G. Womack -- Acting Chief Counsel, NHTSA

TO: Jiro Doi -- Vice President, Mitsubishi North America, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 1/19/95 LETTER FROM Jiro Doi to Philip Recht

TEXT: Dear Mr. Doi:

This is in response to your letter to Philip Recht, former Chief Counsel of the National Highway Traffic Safety Administration (NHTSA), in which you requested an interpretation of the parts-marking requirement of the motor vehicle theft protection standa rd, 49 CFR Part 541.

Your letter asks whether marking the clutch housing on a manual transmission vehicle, or the converter housing on an automatic transmission vehicle, would comply with 49 CFR @ 541.5(a)(2), which requires that the transmission be marked with a VIN or VIN- derivative. Your letter states that the housing is "attached to the transmission via bolts that may be removed allowing the clutch housing (or converter housing) to separate from the transmission."

The answer to your question is that marking the housing but not the transmission would not comply with @ 541.5(a)(2). It is the transmission, and not the housing, that is the component of value to thieves. It is possible that a thief would want to remo ve the transmission from a vehicle without removing the housing, since the transmission is smaller and easier to conceal by itself than it would be with the housing attached. Removal of the transmission alone would be relatively easy to accomplish where the housing is attached to the transmission only by bolts, which is the design you describe in your letter.

If you have any further questions on this matter, please contact Eileen Leahy, an attorney on my staff, at 202-366-5263.

ID: nht95-2.71

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: Ron Hooker -- Program Administrator, Division of Weights and Measures, Missouri Department of Agriculture

TO: Mr. John Womack -- Chief Counsel, NHTSA

TITLE: CNG Motor Vehicle Fuel System Safety

ATTACHMT: ATTACHED TO 6/8/95 LETTER FROM JOHN WOMACK TO RON HOOKER (A43; VSA 103(A) 303)

TEXT: Dear Mr. Womack:

In 1991 the Missouri General Assembly passed legislation mandating a Fuel Conservation Program for state vehicles. Various alternative fuels were addressed in the legislation including natural gas.

At the time the legislation was passed, there were no state regulations setting forth safety standards and/or guidelines for compressed natural gas motor vehicle fuel systems.

Because of the concern for safety and the need for specific guidelines for CNG motor vehicle fuels systems, the Highway Patrol, Public Service Commission and our agency studied the issue and a determination was made that the Missouri Department of Agricu lture should be the "lead" agency since regulations relating to LP gas motor vehicle fuels systems had been established by Agriculture in 1983.

In 1994 the General Assembly passed legislation giving the Department of Agriculture the authority to promulgate regulations relating to CNG motor vehicle fuel system safety. We are now attempting to determine what the extent of the regulations should/c an be.

Several agencies, both private and public, are involved as a rule making committee and anxious for regulations/guidelines to be established so that CNG can be utilized as an alternative motor fuel choice.

With exception of fuel container design and fuel container and system integrity, does the Department of Agriculture have the authority, under federal regulations, to implement regulations and/or adopt national standards (i.e. NFPA 52) relating to CNG mot or vehicle fuel system safety.

If the department does have authority or limited authority, could you please address those areas and communicate them to me at your earliest convenience.

I sincerely appreciate your assistance in this matter.

ID: nht95-2.72

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lance Tunick -- Vehicle Science Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 4/19/95 LETTER FROM LANCE TUNICK TO MARY VERSAILLES (OCC 1085)

TEXT: Dear Mr. Tunick:

This responds to your FAX of April 19, 1995, requesting clarification of an April 3, 1995, letter from this office. You asked for verification that the "seat belt anchorages in the following scenario are exempt from the location requirement of Standard No. 210:

A vehicle with 2 front seating positions that is fitted with an air bag and manual three-point seat belt at each position, and such restraint meets the frontal crash protection requirements of S5.1 of Standard No. 208 with the air bags alone and with the belts and air bags together, but the belts alone are not crash tested under FMVSS 208."

Your understanding is correct.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht95-2.73

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Musa K. Farmand -- Gonzalez & Farmand, P.A.

TITLE: NONE

ATTACHMT: ATTACHED TO 04/27/95 LETTER FROM MUSA K. FARMAND TO MARY VERSAILLES

TEXT: Dear Mr. Farmand:

This responds to your letter of April 27, 1995. Your letter concerns a law suit in which you represent plaintiffs injured in an automobile accident. In this law suit, the counsel for the defendant has moved to amend his answer to assert that 49 CFR 571 .208, paragraph S4.1.5.2(c)(2) requires each state to allow for mitigation of damages in any seat belt use law and that paragraph preempts the Florida mandatory seat belt law. According to your letter, the Florida law "does not allow a mitigation of dam ages defense with respect to an alleged failure to wear a seat belt." As explained below, the National Highway Traffic Safety Administration agrees with you that the Florida safety belt use law is neither expressly nor impliedly preempted by Federal law.

Purpose of Paragraph S4.1.5.2(c) (2)

Before discussing the issue of preemption, I want to discuss the background and purpose of Paragraph S4.1.5.2(c)(2). That paragraph was added to Standard No. 208, Occupant Crash Protection (49 CFR 571.208) as part of a final rule issued July 17, 1984 co ncerning automatic restraints (49 FR 28962). That final rule required all new cars to have automatic protection (air bags or automatic belts) starting in the 1990 model year. The final rule included a provision that the automatic restraint requirement would be rescinded if the Secretary of Transportation determined, not later than April 1, 1989, that a sufficient number of States had enacted belt use laws meeting certain minimum criteria to cover at least two-thirds of the U.S. population (paragraph S 4.1.5). Under S4.1.5, the Secretary was not required to make any determination about any State safety belt laws. In fact, the Secretary never did so, in part because not enough States adopted mandatory seat belt use laws of any sort prior to April 1, 1 989. Because no determination was made under S4.1.5, the automatic restraint requirements are now in effect for all passenger cars.

The minimum criteria were set forth in S4.1.5.2 of Standard No. 208. n1 One of the criteria was "a provision specifying that the violation of the belt usage requirement may be used to mitigate damages . . ." (S4.1.5.2(c)(2)). However, S4.1.5 neither pur ported to require nor was intended to require States to enact safety belt use laws. In addition, S4.1.5 did not require that any State safety belt use laws had to incorporate the minimum criteria of S4.1.5.2. Paragraph S4.1.5 merely provided that the S ecretary would rescind the automatic restraint requirement if he or she determined that a sufficient number of States enacted laws which met the criteria of S4.1.5.2 by April 1, 1989.

n1 Your letter correctly notes that this provision was deleted from Standard No. 208 by a final rule issued on September 2, 1993 (58 FR 46551).

Preemption

The Florida safety belt use law is not and never has been either expressly or impliedly preempted by Federal law.

Standard No. 208 was issued under 49 U.S.C. Chapter 301 which expressly preempts state laws only to the extent provided by section 30103. That section provides for the express preemption of State motor vehicle safety standards that are not identical to Federal standards. However, the Florida seat belt law is not a motor vehicle safety standard within the meaning of Chapter 301, since it does not regulate motor vehicle or motor vehicle equipment performance. Accordingly, the Florida law is not express ly preempted.

The Florida law is not impliedly preempted because (1) Congress has not occupied the field of regulation of the behavior of motor vehicle occupants; and (2) the Florida seat belt law does not conflict with any Federal law or interfere with the objectives of Federal law.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht95-2.74

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Takashi Adachi -- Manager, Ichikoh Industries, Ltd.

TITLE: NONE

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM TAKASHI ADACHI TO RICHARD L. VAN IDERSTIN (OCC 10857)

TEXT: Dear Mr. Adachi:

This is in reply to your letter of March 14, 1995, to Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single re flector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider.

You have asked whether the "structure of the reflex reflector conforms to FMVSS 108," and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bise cted reflector must meet the photometric specification.

Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f. Reflex Reflecto rs January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that sta ndard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors.

If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office.

ID: nht95-2.75

TYPE: INTERPRETATION-NHTSA

DATE: May 10, 1995

FROM: Vladimir Salita

TO: Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 7/2/95 LETTER FROM JOHN WOMACK TO VLADIMIR SALITA (A43; STD. 201; STD. 104; STD. 108; VSA 102); ALSO ATTACHED TO 5/11/95 LETTER FROM JOHN WOMACK TO TERESA THOMPSON; ALSO ATTACHED TO 7/30/95 LETTER FROM JOHN WOMACK TO WAYNE FERGUSON (STD. 108)

TEXT: Dear Sir:

I am taking the liberty to write you. I have been advised by Mr. Vaniderstine to address to you this letter. Being an electronic engineer I came to some ideas related to improving safety of driving. I hope the inventions I made might be very useful and patentable.

My ideas are now in different stages of developement: some of them have been realized in working models, others need futher research and testing. Before taking next step I would like to be sure that my inventions are in accordance with existing stand ards. Also I would very appreciate your opinion on usefulness of the inventions.

The brief descriptions of the inventions are enclosed.

Thank you for your time and attitude.

Enclosure

WARNING AND TEACHING DEVISE FOR IMPROVING OF

DRIVING HABITS AND FUEL ECONOMY.

This is a simple, easy-to-install devise, which is to warn drivers by indicating the excessive deceleration, acceleration and dangerous speed at turns by emitting sound signals. Such warning will teach motor vehicle drivers how to take adequate and s afe actions and to improve fuel economy. This devise can be adjustable for different levels of the controlled parameters or / and be factory-preset to the predetermined values.

This inexpensive, dashboard-mounted devise can be powered from separate battery or cigarette lighter and the installation does not require any experience.

The working model is available.

DECELERATION WARNING LIGHT.

The devise measures actual vehicle deceleration and its output controls the frequency of light flashing (preferable high-mounted brake light). This makes following vehicles drivers alert and thus reduces risk of rear-end collisions.

The devise proposed is inexpensive, small sized and easy-to-install.

There are several patents related to the given invention, which, however, differ from the proposed one those show that the problem is still actual and the solution is very desirable.

The working model is available.

SELF-ADJUSTABLE WINDSHIELD WIPER.

This devise controls the rate of windshield wiper sweeps according to intensity of rain, thus it eliminates the distraction of driver's attention and makes driving more comfortable. This is to improve traffic safety. It needs no additional sensors, such as humidity sensors or windshield transparency sensors.

ID: nht95-2.76

TYPE: INTERPRETATION-NHTSA

DATE: May 11, 1995

FROM: Dennis T. Snyder, Esq.

TO: David Coleman -- NHTSA Administrator

TITLE: NONE

ATTACHMT: ATTACHED TO 6/14/95 LETTER FROM JOHN WOMACK TO DENNIS T. SNYDER (PART 566)

TEXT: Dear Mr. Coleman,

I have a client engaged in the manufacture of completed heavy duty dump trucks, vans and road tractors. The client obtains chassis-cabs previously produced by an intermediate manufacturer and adds dump bodies, van bodies or fifth wheels. The uniquen ess of the clients business is that the manufacturing work is performed on used chassis-cabs. For example, a chassis-cab which has been used as a road tractor for an indeterminate period may be manufactured into a dump truck by the removal of the fifth wheel and addition of a dump truck body.

The question is whether the client is a "final stage manufacturer" within the meaning of the National Traffic and Motor Vehicle Safety Act and, specifically, Parts 566, 567 and 568 of the regulations. (49 CFR 566, 567 and 568.) Stated another way, is the client relieved of an obligation to perform the certifications which would otherwise be required under Parts 567 and 568 because he is performing his manufacturing operations using used chassis-cabs rather than new ones?

ID: nht95-2.77

TYPE: INTERPRETATION-NHTSA

DATE: May 11, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Scott E. Mack -- Senior Product Manager, Philips Lighting Company

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM SCOTT E. MACK TO CHIEF COUNSEL, NHTSA (OCC 10269)

TEXT: Dear Mr. Mack:

This is in reply to your letter of April 24, 1995, requesting a confirmation of your interpretation that "Philips Color Clear (TM) Halogen Headlights . . . are in compliance with FMVSS-108."

The product in questions "appears to be colored when not in use" but "when lighted it produces white light as defined by J579C." You have provided a report from ETL Testing Laboratories which "indicates that the color of the light is identical to that of a standard halogen headlight."

There is no definition of white light in SAE J579c Sealed Beam Headlamp Units for Motor Vehicles, December 1978. We believe you mean SAE J578d Color Specification for Lighting Devices, September 1978 which does contain a definition expressed in chromati city coordinates. The report you supplied indicates that the Philips lamp provides a light within the color coordinates for white when equipped with a red, black, blue, or white insert. As Standard No. 108 contains no requirements for the color of glas s lamp lenses or bulbs, only the light emitted from the lamp, we confirm your conclusion that the Philips Color Clear (TM) headlamp has been designed to conform to the color requirements of Standard No. 108.

We appreciated your visit to NHTSA on April 26 to demonstrate the lamp with its various inserts. I understand that the light produced by the lamp, and by a standard headlamp, appeared identical to the naked eye in a side by side comparison.

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

ID: nht95-2.78

TYPE: INTERPRETATION-NHTSA

DATE: May 11, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Teresa Thompson

TITLE: NONE

ATTACHMT: ATTACHED TO 4/6/95 LETTER FROM TERESA THOMPSON TO NHTSA (OCC 10849)

TEXT: Dear Ms. Thompson:

We have received your letter of April 6, 1995, with respect to an automotive deceleration signal. You have asked for information "on how to have this product tested and approved as well as information on the legal ramifications and liabilities for the p roduct."

The Department of Transportation neither tests nor "approves" products. What it does do is to advise whether motor vehicle equipment is permitted under the statutes and regulations for whose administration it is responsible. In this instance, the appro priate regulation is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. This standard specifies requirements for only certain items of lighting equipment but it also has an effect on lighting equipment that is not specified in the standard. That is to say, if an item of lighting equipment is not allowable for a manufacturer or dealer to install as original equipment (i.e., equipment on the vehicle at the time of its original sale), in most cases it won't be allowable in the aftermarket for manufacturer or dealer installation on used vehicles as well.

As you describe it, the signal is provided by "a strobe light with an independent power supply, which upon heavy breaking (sic), will activate a strobe for five seconds and on impact for ten minutes." The prototype "is approximately 4" by 3" and may be a ttached to a rear window."

Federal laws cover brake activation of your strobe signal. Standard No. 108 requires turn signal lamps, hazard warning signal lamps, and school bus warning lamps to flash. Headlamps and side marker lamps may be flashed for signaling purposes. But all other lamps provided as original equipment must be steady-burning. We regard a strobe lamp as one that flashes. For this reason, the deceleration signal you describe could not be installed as original equipment. Further, its installation on a used veh icle would take the vehicle out of compliance with Standard No. 108.

Notwithstanding the discussion above, there is no Federal prohibition on the sale of the strobe signal device, and Federal law does not prevent the vehicle owner from installing it on a used vehicle (however, manufacturers, dealers, distributors, and mot or vehicle repair businesses may not do so), no matter what effect the strobe signal may have upon compliance with Standard No. 108. However, the States have the right to decide whether use of the strobe signal is permissible. We aren't able to provide you with information on State laws, and suggest that you seek an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22303. We can't advise you on your potential liabilities either, and suggest th at you contact your attorney for an opinion on the applicability of local law.

In addition, it is important to note that Standard No. 108 prohibits supplementary original lighting equipment that impairs the effectiveness of the original lighting equipment required by Standard No. 108. The proximity of your strobe device in the rea r window to the center highmounted stop lamp required by Standard No. 108 raises the possibility of impairment, especially if the strobe is of a color other than red, or so bright as to mask the center stop lamp signal.

I am sorry to be unable to offer you more encouragement at present, as we share your concern with the negative effects of fog and rain on drivers and vehicles. It is obvious that you have given much thought to this problem. Noting that you are testing a prototype, this agency would be interested in receiving any data you have or may develop showing a positive effect of the strobe signal upon the frequency and severity of rear end collisions. You may send this to Michael Perel, Office of Research and D evelopment, NHTSA, Room 6206, 400 Seventh St. SW, Washington, DC 20590. It is conceivable that at some time in the future we would allow the center stop lamp to flash under conditions of rapid deceleration. This could open the way to permissibility of an additional lamp such as yours.

I note that, to the extent that your device were only to activate upon impact and not during conditions of rapid deceleration, it would not be prohibited by Standard No. 108. Such a device would be permissible as a supplement to, or substitute for, a ve hicle's hazard warning signal system. We do not know whether it would be permissible under State laws (see discussion above).

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

ID: nht95-2.79

TYPE: INTERPRETATION-NHTSA

DATE: May 12, 1995

FROM: K. Howard Sharp -- Attorney at Law, Arnason Law Office

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/7/95 LETTER FROM JOHN WOMACK TO K. HOWARD SHARP (A43; REDBOOK 2; STD. 108)

TEXT: Dear Mr. Womack:

Our firm represents NYTAF Industries, Inc. of Edmore, North Darora. NYTAF has developed a device known as Safety Bright(R) which is an auxiliary signalling system for heavy duty vehicles. I have enclosed for your consideration a draft of a brochure NYTAF intends to distribute when it begins to manufacture and market the device. Exhibit A, attached. Additionally, Exhibit B provides an explanation of the product's functions.

On May 9, 1995 I spoke to Mr. Taylor Vinson who suggested we request a written opinion from N.H.T.S.A. regarding the applicability of the federal motor vehicle safety standards to Safety Bright(R). Mr. Vinson expressed concern that Safety Bright(R) m ight violate Standard 108 by impairing the effectiveness of required lighting equipment. See 49 C.F.R. @ 571.108 (S 5.1.3). Mr. Vinson declined to offer an opinion, however, since he had not seen the device and knew nothing of it. Consequently, NYTAF now requests a written opinion from N.H.T.S.A. regarding the compliance of Safety Bright(R) with federal motor vehicle safety standards.

The attached brochure describes Safety Bright(R) and illustrates the product as it would appear installed on the rear of a semi-trailer. The unit mounts on the rear of the trailer frame directly below the trailer body in the center putting the displa y panel on approximately the same horizontal plane as the tail lights, and brake lights.

Safety Bright(R) displays a verbal message appropriate to the particular potential hazard. The red L.E.D. (light emitting diode) panel displays the auxiliary warnings listed in Exhibit B. NYTAF originally designed and manufactured prototype devices with the option of displaying the word "Thanks" but recently decided to delete that message.

Safety Bright(R) does not interfere with lighting required by Standard 108. Safety Bright(R) connects to the tractor's power source through the pigtail connection. While certain functions operate in conjunction with existing lighting; such as turn si gnals and brake lights, if the Safety Bright(R) unit were to fail, the existing lamps and signals would continue to operate normally.

The L.E.D. display is somewhat more intense than existing brake lights, turn signals and tail lamps. NYTAF believes the greater intensity attracts attention to the vehicle and to the message conveyed by the conventional signals but does not detract f rom the visibility and conspicuity of existing equipment. The greater intensity, while averaging less than one candlepower per L.E.D., enhances Safety Bright's(R) visibility in bright daylight.

One might argue that Safety Bright(R) could constitute a distraction and thereby decrease the effectiveness of existing signals and lights required under the regulations, See 49 C.F.R. @ 571.108 (S 5.1.3). We do not agree. To the extent Safety Brigh t(R) might cause such a distraction, it would result only from the product's novelty after its introduction to the market. Safety Bright(R) should create no more of a distraction than reflective tape, retroreflective strips, side marker turn signals, or fuel efficient, aerodynamically designed truck bodies. NYTAF is confident the motoring public would readily accept and undoubtedly benefit from the use of Safety Bright(R) on trucks and semi-trailers.

Anecdotal evidence suggests N.H.T.S.A. has considered and rejected a number of somewhat similar products in the past. "Message boards" mounted in car windows and L.E.D. advertising signs mounted on automobiles do create a distraction and a consequent traffic hazard. Safety Bright(R) differs from such devices because it displays only standard traffic related messages. Drivers cannot display their own personal messages or commercial advertising, and they cannot alter the messages programmed into the unit. Therefore, the reasons for rejecting seemingly similar products submitted to N.H.T.S.A. in the past simply do not apply to Safety Bright(R).

NYTAF believes Safety Bright(R) fully complies with the federal motor vehicle safety standards. As an enhanced auxiliary signalling device, Safety Bright(R) operates in conjunction with existing, required equipment and furthers the purpose of the app licable standard, which purpose is

to reduce traffic accidents and death and injuries resulting from traffic accidents, by . . . enhancing the conspicuity of motor vehicles on the public roads so that, their presence is perceived and their signals understood, both in day light and in dark ness or other conditions of reduced visibility."

49 C.F.R. @ 571.108 (S2). This is exactly the same purpose for which Safety Bright(R) was designed.

Ironically, heavy trucks and semi-trailers -- the largest vehicles on our roadways -- have a profound need to increase conspicuity, especially with respect to speed and signals, See generally Exhibit C. Retroreflective strips and reflective tape repr esent recent advances in this area. Nevertheless, the trucking industry along with the general motoring public stand to benefit from an enhanced signalling system for heavy duty vehicles such as semi-trailers. Studies show that most semi-trailer acciden ts occur on city streets at speeds of less than eighteen (18) miles per hour. Exhibit C. Safety Bright(R) offers a special advantage for traffic safety under those circumstances by giving a clear and conspicuous warning to drivers and pedestrians at th e rear of the vehicle of the operator's intended maneuver.

At highway speeds, Safety Bright(R) should give other motorists extra reaction time in many instances because of the bright, clearly visible and unambiguous message. Experienced drivers know that even an extra half second of reaction time can sometim es mean the difference between an appropriate response and a tragedy. NYTAF believes Safety Bright(R) would give motorists a more obvious indication of a truck's intended maneuver, thereby alerting other drivers more quickly and decreasing reaction time s.

Other messages such as "WIDE LOAD," "LONG LOAD," "BACKING," "CAUTION" and "HELP" draw attention to the special circumstances indicated. The wide or long load messages supplement existing requirements for appropriate markings to increase awareness of the size of the vehicle. The backing signal visually alerts motorists and pedestrians to the truck's directon of motion whereas no regulation currently requires a visual backing signal for semi-trucks. The caution signal works in conjunction with the e mergency flashing signals. The help signal quite obviously is a summons for assistance intended for use by operators of disabled trucks.

Attached as Exhibit D are the schematic diagrams of the Safety Bright(R) device and other pertinent electronic date. If you need any additional information, please let us know. The manufacturer will gladly meet with N.H.T.S.A. officials to demonstra te the product and to discuss any aspect of its construction or operation. NYTAF is eager to consider any comments or suggestions for improvement.

Thank you for your attention to this request. We look forward to your response. With best regards, I am

(Brochure and exhibits omitted.)