Interpretation ID: nht94-3.52

TYPE: INTERPRETATION-NHTSA

DATE: July 1, 1994

FROM: Samson Helfgott -- Helfgott & Jaras, P.C.

TO: Paul Jackson Rice, Esq. -- Chief Counsel, NHTSA

TITLE: Our Ref. No.: 12.065

ATTACHMT: Attached to letter dated 7/20/94 from John Womack to Samson Helfgott (A42; STD 108), letter dated 3/30/89 from Ericka Z. Jones to Samson Helfgott, and letter dated 9/17/90 from Paul Jackson Rice to Samson Helfgott

TEXT: We represent Harold Caine, President of the S.A.F.E. Foundation (Safety Autodrivers Foundation for Education). This organization is actively working to promote highway safety through reduction of automobile accidents. Over the past years, they suggeste d the use of an amber lamp provided adjacent the rear end high mounted red brake lamp and positioned in a separate control and arrangement so as not to impede the operation of the brake lamp. The amber lamp remains on as a "day time driving lamp" as lon g as the car is being operated. When the brake is applied and the brake lamp goes on, the amber lamp goes off. This concept has been discussed with your office and I enclose copies of two previous letters from your office addressing this matter. This concept has already been tested on trucks and has been found to provide substantial reductions in rear end collisions.

Mr. Caine is considering the possibility of utilizing this combination of red and amber lighting arrangement to be placed along the sides of trucks and other vehicles. They would operate in conjunction with the red and amber lights on the rear of the vehicle. Thus, the amber lights on the

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side would remain on in conjunction with the amber lights at the rear of the vehicle during normal driving of the vehicle. When the brake is applied, the amber lights would automatically turn off and the brake lights on the rear of the vehicle would go on and in conjunction therewith, the red lights on the side of the vehicle would also turn on. Please note that the operation of the brake light is not impaired by the presence of the amber lights so that the brake lights operate directly upon applicati on of the brake independent of the turning on and off of the amber lights.

I would appreciate knowing whether the presence of the red and amber lights on the sides of the vehicle would be permissible under Standard No. 108 and, to the best of your awareness, whether there are any prohibitions that might prevent utilization o f this structure on the sides of the vehicles.

I would appreciate hearing from you on this matter.

Enclosure