Interpretation ID: nht87-1.59
TYPE: INTERPRETATION-NHTSA
DATE: 04/03/87
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Tony U. Otani
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Tony U. Otani Adyna Corporation 6124 Candor Street Lakewood, CA 90713
Dear Mr. Otani:
This letter responds to your letter asking whether there are any 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 you describe is a thick urethane 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 Highway 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 originally 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 vehi cle...(Emphasis added)
In determining whether an item of equipment is an "accessory," the 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 ordi nary users of motor vehicles. Under this framework, your invention is a motor vehicle accessory.
While NHTSA currently has no standard applicable to the kind of accessory you describe, the agency does 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 re gulations 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. This 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, and hope you find this information helpful in making your decision.
Sincerely,
Erika Z. Jones Chief Counsel
Adyna Corporation 6124 Candor St. Lakewood, CA 90713
To:
Director National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, DC 20590
Dear Sir,
I have an invention (patent pending) and planning for the production of;
Automobile Steering Wheel Stabilizing Aid
as shown in the enclosed picture.
It made of special contoured pad, with gripping soft material such as urethane rubber, with fastening means to left leg such as clamps as shown, or a band with buckle.
Please let me know by return if there are any regulations we have to comply.
Very truly yours,
Tony U. Otani
P.S. The device will function as follows:
This device will help to drive on a long distance highways when in a streight course. The driver can simply lift up left leg to create pad contact to, the wheel to hold it. He can also simply reverse the course for a freedom of steering, It reduces vibra tion to hands and make driving easier and will not interfere steering action when dissociated.
It can be further modified with an alarming devise built in, with a pressure switch to actuate a buzzer. When the driver falls in sleep he would tend to release the leg force and thus to actuate the alarm.