Interpretation ID: nht95-2.57

TYPE: INTERPRETATION-NHTSA

DATE: April 27, 1995

FROM: Mayo D. Tubbs -- Visionary Lighting Systems

TO: Philip Recht -- Acting Deputy Administrator, NHTSA

TITLE: Revised High-Technology Lighting System for the Trucking Industry

ATTACHMT: ATTACHED TO 6/9/95 LETTER FROM JOHN WOMACK TO MAYO D. TUBBS -- (A43; STD. 108)

TEXT: Dear Mr. Recht:

I was disappointed to ascertain from your correspondence dated April 13, 1995 that my color selection of Aviation Green for the strip lighting system would not conform to Standard No. 108. While I feel strongly that the unique green color would incre ase drivers' visual acuity and enhance identification of trailers in low light and inclement weather conditions, the system is not limited to the color green. Subsequent discussions with Mr. Taylor Vinson concerning the use of amber and red colored stri p lights indicate the system may comply with Standard No. 108 if these colors were utilized in lieu of green. Attachment A provides color locations of the strip lights.

Selection of the proper red and amber colors will conform to CIE 1931 and 1976 UCS Chromaticity Diagrams. Amber will be in the 580 nanometer range while red will be in the 610 nanometer range.

All other system specifications remain the same as the original design. Light output will be in the 4fL range, the system power input requirement will be less than 1 amp D.C. and the physical shape of the lights will be the same. The inherent safety f eatures of the previously submitted lighting system will apply to red and green strip lights also.

Concerning the physical locations of the strip lights and the possible interference with the conspicuity reflective tape along the sides and rear of the trailer. I understand that covering or partial obscuration of the reflectivity tape will decrease tape effectiveness and consideration will be given in selecting proper areas of strip light installation. Mr. Taylor noted that new production trailers must have the reflective tape installed at the top, rear of the trailer in accordance with S5.7. Mo st trailers provide sufficient area to accommodate both the tape and the strip lights. If not, then no lights would be installed in this area. Attachment B provides additional information.

It is my understanding that if a trailer manufacturer installs the three identification lights at the top, rear of the trailer, then the clearance lights can be installed at the bottom of the trailer. If the identification lights are mounted at the b ottom of the trailer, then the clearance lights must be at the top, rear. See attachment C.

To provide a better understanding of this technology and the proposed lighting system, I can provide an on-site demonstration for the NHTSA and for George Parker of the Office of Research and Development.

I hope that this information concerning the revised lighting system will provide your office wilh sufficient data to evaluate the system and rule that it is in compliance with the requirements of 49 U.S.C. 30112(a).

Thank you for your time and consideration and I look forward to receiving your letter.

(Attachments A-C omitted.)