Interpretation ID: nht93-5.21

TYPE: Interpretation-NHTSA

DATE: July 12, 1993

FROM: Cary Klingner -- Trison Inc.

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 from John Womack (signature by Kenneth N. Weinstein) to Cary Klingner (A41; Std. 108; VSA 108(a)(2)(A)h

TEXT:

TRISON INC. has developed a "Daytime Running Lights" module. The product keeps the low beam headlamps on whenever the vehicles engine is running. The module is placed under the hood and can be installed by any car owner. The unit is transparent to the vehicles lighting system thus allowing the headlamp and marking light switch to override it at any time. The product connects to the battery positive terminal, the highbeam headlamp, the lowbeam headlamp and one simply wraps around one spark plug wire.

The unit was developed because of the Minnesota law that requires headlamps to be on during daylight inclement weather. This law has created a problem in that some people forget to turn on their lights when required, or forget to turn them off when they leave their vehicle, which runs down the battery. Our unit will alleviate both problems if the driver does not override the module with the vehicle headlamp switch. The Minnesota law only requires that the headlamps be on so with our module no other lights or markers will be illuminated.

We understand that federal regulations were modified earlier this year that may affect this concept and we would like to market this product nationwide. Would you review our safety device and give us an opinion as to whether it complies with the regulations.

Thank you for your time, your response will be greatly appreciated.