Interpretation ID: aiam4286
Adyna Corporation
6124 Candor Street
Lakewood
CA 90713;
Dear Mr. Otani: This letter responds to your letter asking whether there are an regulations with which you must comply in producing an invention you call an Automotive Steering Wheel Stabilizing Aid. I regret the delay in this response.; You describe your product and include a picture. The article yo describe is a thick urethan rubber pad that a motor vehicle driver can fasten to the thigh with a band or buckle. The top part of this pad is contoured to fit under the steering wheel. You state that a driver can use this pad to apply pressure to the steering wheel, holding the wheel steady so that he may drive on a long distance highway when the course is straight. The driver then has his hands free.; Your product falls within the jurisdiction of the National Highwa Traffic Safety Administration (NHTSA) if it is an item of 'motor vehicle equipment' as that term is defined in S102(4) of the National Traffic and Motor Vehicle Safety Act. Section 102(4) defines 'motor vehicle equipment' in relevant part as follows:; >>>...any system, part, or component of a motor vehicle as originall manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component, or as any *accessory*, or addition to the motor vehicle...(Emphasis added.)<<<; In determining whether an item of equipment is an 'accessory,' th agency assesses two factors: first, whether the item has no ostensible purpose other than use with a motor vehicle, and second, whether the item is intended to be used principally by ordinary users of motor vehicles. Under this framework, your invention is a motor vehicle accessory.; While NHTSA currently has no standard applicable to the kind o accessory you describe, the agency does not have authority to regulate your invention. Even in the absence of a standard, please note that if you decide to market this product, then under our regulations and the National Traffic and Motor Vehicle Safety Act, you have the responsibility to conduct notice and remedy campaigns if you or the agency later find that your product has a safety-related defect.; We are concerned with the safety consequences of your product. Thi kind of product may encourage a driver to take his hands from the steering wheel while he is operating a motor vehicle, and therefore may increase the risk of accident involving a motor vehicle. For example, removing one's hands from the steering wheel makes a driver less efficient in responding to any unanticipated road event that may require a quick change in vehicle direction. Further, a driver who feels free to do something with his hands other than steer the vehicle may not be devoting full time and attention to his driving.; I ask you to give these implications your fullest consideration, an hope you find this information helpful in making your decision.; Sincerely, Erika Z. Jones, Chief Counsel