Interpretation ID: nht94-3.81

TYPE: INTERPRETATION-NHTSA

DATE: July 25, 1994

FROM: Kover, Joe

TO: Medlin, Jere -- NHTSA

TITLE: NONE

ATTACHMT: Attached To A Letter Dated 10/14/94 From Philip R. Recht To Joe Kover (A42; STD. 108)

TEXT: I am writing to you for your opinion regarding an electronic circuit which I have designed for use in motor vehicles. The device to which I refer is the Light Control Unit (LCU) which currently has a patent pending. The LCU is designed to perform the f unctions which are frequently ignored by the motor vehicle operator. The LCU may easily be integrated into the light system of new production vehicles or currently registered vehicles.

The LCU automatically turns off the head and tail/park lights when turning off the ignition switch, therefore, circumventing the inadvertent discharge of the battery.

The LCU automatically turns on the head and tail/park lights in conjunction with the windshield wiper switch and the lights will remain on until the ignition switch is placed in the off position. This feature precludes the operator from inadvertently turning off the head and tail/park lights, during the hours of darkness, when placing the windshield wiper switch in the off position.

The use of the motor vehicle windshield wipers is generally in conjunction with adverse weather conditions which results in poor visibility.

The LCU also extends an exclusive feature over other light units, this feature is the Light Bus Monitor.

The Light Bus Monitor in combination with the auxiliary circuit automatically restores the head and tail/park lights if the LCU should fail.

The LCU also can be employed as a Daytime Running Light (DRL) unit by maintaining the light switch in the on position. However, unlike conventional DRL units the LCU gives the operator the latitude to make this determination. Also, the LCU allows the op erator to turn off either the head lights only or both the head and tail/park lights via the light switch. Furthermore, unlike conventional DRL units which fail to automatically turn off the lights with the light switch in the on position and the igniti on switch in the off position, the LCU does automatically turn off the lights. Therefore these concepts in conjunction with the Light Bus Monitor serve to make the LCU a more desirable alternative over conventional DRL units. However, one question does surface, would a motor vehicle operator be in violation of the federal motor vehicle safety standards by maintaining both the head and tail/park lights on during the hours of daylight?

In conclusion based upon the information contained herein, does the LCU meet the federal motor vehicle safety standards? Also, could the LCU be integrated into the light system of new production vehicles or currently registered vehicles; I remind you th at the LCU is not a DRL unit. However, the LCU may be employed as a DRL unit, and if the operator should elect to employ the LCU as a DRL unit does it meet the federal motor vehicle safety standards? Also, could you please include the federal specifica tions for electronic devices. Please forward your expeditious response to me at the above address.