Interpretation ID: 86-2.34

TYPE: INTERPRETATION-NHTSA

DATE: 04/23/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Rudi Haenisch -- Manager Sales, Brisson Development, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Rudi Haenisch Manager Sales Brisson Development, Inc. 13845 Nine Mile Road Warren, Michigan 48089

Thank you for writing on March 19, 1986, and telling me about your strobe lamp which plugs into cigarette lighter sockets and which is intended to serve as a supplementary warning device. I assume that you want to know our views as to its legality.

This type of aftermarket accessory is not covered by Standard No. 108. the Federal motor vehicle safety standard on motor vehicle lighting, and there are no Federal restrictions on its sale or use. This means that its permissibility must be determined by the laws of each jurisdiction in which it is to be sold and/or used, and it is our impression that many States may restrict the use of strobe lamps to defined emergency vehicles engaged in emergency missions.

Sincerely,

Erika Z. Jones Chief Counsel

March 19, 1986

Mrs Erika Z. Jones - Chief Council National Highway Traffic Safety Administration Room 5219 400 Seventh Street S.W. Washington, D.C. 20590

Dear Mrs. Jones;

On March 18, 1986, I talked by phone with Mr. Steve Oesch and he informed me to send this letter to you.

Brisson Development Inc. has designed two different 'Emergency Strobe Lights' for the auto aftermarket geared toward the owners of Light trucks and automobiles. They are designed to be magnetically mounted on the vehicle and just plug into the cigarette lighter receptacle. Thereby providing additional safety warning to traffic and in some cases the only warning (if the vehicles OEM flashers have failed) that the vehicle is a hazard to other traffic.

As I am sure you are aware of the many different types of vehicle emergency aid devices available on the market today. Ranging from reflectors, which for some reason people like to run over, to mechanical triggered standard light bulb devices, which have about the same reliability of a flashlight that has not been in use for six months and when you need it it does not work. I personally, and people I know, have bought and tried just about every emergency aid type device and have really not been happy with any of them. That is why at Brisson we are looking to make a quality emergency light that will be reliable after long periods of time that it has not been used or tested and then function properly in any kind of weather.

Why a strobe light instead of making just another me to item?

1. Reliability of the electronic circuit - the strobe light was designed from conception to provide high candle power flashing lights from short to Long time usage.

2. No mechanical parts to wear out, corrode, or malfunction.

3. High candle power output with low electric current draw as compared to regular bulbs and their flasher unit.

4. Low cost of unit per candle power.

5. Many emergency and road work vehicles have and are changing to strobe units.

6. The fast high intensity light flash of strobes triggers an attentive response from the human brain and points out a hazardous condition.

7. Strobes are new on the highway market, and have not created a mental block as some other emergency devices, just look at the average life of a road construction or work sign, we may look at designing a spaced strobe for this problem also.

Descriptions of the two emergency strobe units are as follows:

SL 70 K Emergency Strobe Light - Puts out 70,000 candlepower of light. Comes with a cigarette lighter plug and just over ten feet of twenty guage wire insulated cord.

A strong magnet has been put in the bottom of the unit so it can be mounted anywhere on the outside of the vehicle and not fall or get blown off. An amber high strength plastic lens has been provided since amber is a universal emergency color. A high strength plastic bottom has been chosen for its non-corrosive qualities. The top lens and bottomhousing screw together for ease of service should anything happen to the top lens for replacement. The top amber lens has a refractive design to diffuse the light evenly. Provides a full 360 degree field of vision, especially in situations where a vehicle has been parked at an angle to the road where its OEM flashers cannot be seen from the road. The bulb flashes at a rate of four times per second and is a clear xenon gas filled type. A polished reflective surface has been put on the inside just below the bulb to reflect all the Light through the amber Lens. Dimensions are 41/2 inches high by a 3 inch round diameter with a rounded dome top.

SL 140 K Emergency Strobe Light - Puts out 140,000 candlepower of light. Comes with a cigarette lighter plug and a twenty five guage, ten foot coilable, insulated cord. Three high strength magnets have been put on the bottom (saving weight) and providing stability so the unit can be mounted anywhere on the outside of the vehicle and will not fall or get blown off. An emergency yellow high strength plastic lens has been provided since it is a universally accepted emergency color. A high strength plastic bottom has been chosen for its non-corrosive qualities. The top lens and bottom are held together by three evenly spaced phillips heads screws coming up through the bottom casing and screwing into the out top lens and do not show, and thereby making the unit easily serviced. The top emergency yellow lens has a refractive design to difuse the light evenly. Provides a full 360 degree field of vision, especially in situations where a vehicle has been parked at an angle to the road where its OEM flashers cannot be seen from the road. The bulb flashes at a rate of two times per second and is a clear xenon gas type. Future units may have two bulbs instead of one. A polished reflective surface has been put on the inside just below the bulb to reflect all the light through the yellow Lens. Dimensions are Top Lena 2 3/8 inches tall by 3 5/8 inches round diameter with a flat top; Bottom Casing is 1 1/2 inches tall by 4 3/4 inches round diameter; Total height is 3 5/8 inches since the top lens and bottom casing slightly overlap.

The above two emergency lights were designed cosmetically to meet the different conditions they will be functioning in, but also to be pleasing to the buying public.

In the future, after more research has been done, I might be interested in discussing the possibility of manufacturing strobe Lights as OEM emergency flashers for automobiles and light trucks, and also new concepts for the heavy trucking industry.

Thank you for your valuable time. If you have any questions, please feel free to contact me at the above address, or by phone (1-800-824-5106).

Sincerely,

Rudi Haenisch Manager Sales

RH/DC