Technology vs. Government Regulations

Yesterday I talked about when the technology that makes "Instinctive Brake light Illumination" possible was available. Today I am going to answer the question that we most often hear. "Why hasn't someone done this before?".

There are many possible reasons that this hasn't been done until now. The first reason that I will reject is because the technology was not available. As I said yesterday, the technology was available as soon as the hall effect speed sensor was available. A more probable answer is government regulations and interpretation of these regulations.

When we first started this project, we went to the Federal Motor Carrier's Safety Regulations handbook. The first section that we used to determine allowance of Slow-N-Tell was  §393.1 Scope of the rules in this part. This section states that "the rules in this part establish minimum standards for commercial motor vehicles as defined in §390.5 of this title." Meaning, essentially, that the rules that are defined in section 393 of the FMCSR are only the least of what is required, not limiting additional safety measures as long as they do not interfere with other protocols or reduce the safety of operation of the motor vehicle in question. We saw this as good news for our project.

The second regulation that we faced was §393.3 Additional equipment and accessories.  This section states that "Nothing contained in this subchapter shall be construed to prohibit the use of additional equipment and accessories, not inconsistent with or prohibited by this subchapter, provided such equipment and accessories do not decrease the safety of operation of the motor vehicles on which they are used." Since the brake pedal and Johnny bar still work in the manner required by §393.25 Requirements for lamps other than head lamps, it can safely be stated that Slow-N-Tell does not decrease the operation of the motor vehicle on which it is used. This was also a good sign.

The third section that was brought to our attention gave us a bit of concern. §393.25 Requirements for lamps other than head lamps states "The stop lamps on each vehicle shall be activated upon application of the service brakes." While this appears to state is that the only way to activate the brake lights is to use the service brake (brake pedal or Johnny bar). This is not the case. Having spoken to many Highway Patrolmen and FMCSA Inspectors, what this really means is that when you step on the brake pedal or pull on the Johnny bar, the brake lights illuminate. This is still the primary protocol when Slow-N-Tell is installed in a truck. The brake pedal and Johnny bar still turn on the brake lights. I am certain that many who looked at this regulation misunderstood it and this may actually be one of the major reasons that this type of technology did not happen until now.

Other reasons that have been tossed around is the lack of need for a product of this type, but when one looks at the problem with logic and objectivity, it is easy to see that the need is there. A more likely reason is that people simply do not understand alternative braking methods used by truckers. We have found, through hundreds of conversations with people at trade shows and expos, that many people do not realize that engine braking and downshifting do NOT turn on brake lights. We are doing our best to educate drivers to this lack of warning. As a matter of fact, this is the main reason that I began this blog, to educate drivers.