ID: nht79-1.43

DATE: 01/12/79

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 27, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. Specifically, you asked whether it is permissible to use symbols for the parking lamp functions of the headlamp switch, in addition to the headlamp symbols required in Table I of the Standard.

The answer to your question is yes. Section 5 of the standard states that each passenger car "with any control listed in S5.1 or in column 1 of Table 1, . . . shall meet the requirements of this standard for the location, identification, and illumination of such control or display." Since no symbols or other designations are required under the standard for parking lamps where their control is not combined with that for headlamps or for "lamps-off" positions on controls, it is up to the manufacturer whether to label these additional functions and whether to use words or symbols. Footnote 2 of Table 1 of the standard does provide that a manufacturer must use the single headlamp symbol to designate several functions when clearance, identification, parking and/or side marker lamps are all controlled with the headlamp switch. This footnote was not intended to preclude additional symbols for these other functions, however. In fact, S5.2.1 provides that "additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity."

Regarding your drawings, clearance lamps are listed in paragraph S5.1 and in column 1 of Table 1 of the standard. Therefore, they must be identified by the symbols shown in column 3 of Table 1 or by the words "Clearance Lamps" or "Cl Lps". The "parking right and left" symbol shown on the drawing submitted with your letter would not satisfy the requirements for clearance-lamp designations. However, the symbol labeled "Clearance Lamps" that appears on the drawings which Mr. Gebhard M. Hespeler and Mr. Craig Jones submitted on December 20, 1978, would conform with the requirements. I have enclosed a copy of that drawing.

If you have any further questions, please do not hesitate to write.

SINCERELY,

November 27, 1978

National Highway Traffic Safety Administration Office of Chief Counsel

Re.: Request for Interpretation - FMVSS 101-80

Dear Madam or Sir:

Federal Motor Vehicle Standard 101-80, Controls and Displays, specifies symbols for identifying certain functions of hand-operated controls, but does not address the parking lamp function of the headlamp switch other than the reference contained in Footnote 2 Table I. We suspect this footnote statement is to simplify requirements for providing symbols on those switches, all of whose functional positions cannot readily be identified, such as push-pull switches. An interpretation is therefore requested as to whether or not it is permissable to use additional symbols for the parking lamp functions in addition to the headlamp symbols required in Table I of this standard. An example of such headlamp switch markings is shown in the attached drawing. This rotary switch has the following corresponding functions:

Full counter-clockwise; parking lamps, left-hand side of vehicle, ignition off.

Next position clockwise; parking lamps, right-hand side of vehicle, ignition off.

Vertical/middle position: all lamps off.

Next position clockwise; parking lamps and side marker lamps left and right, - ignition on or off.

Full clockwise; headlamps, parking and side marker lamps.

We would appreciate receiving your interpretation of this standard at your earliest convenience. Do not hesitate to contact this office should you require further information on the switch described.

HEINZ W. GERTH

Request for Interpretation - FMVSS 101-80

Mercedes-Benz of North America, Inc.

(Graphics omitted)

ID: nht79-1.44

DATE: 04/06/79

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Leyland Cars

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your July 17, 1978, letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.

You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.

You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those item. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.

SINCERELY,

Engineering and Product Planning Division

British Leyland UK Limited

The Administrator, National Highway Traffic Safety Administration,

JULY 17, 1978 Dear Madam,

PETITION FOR RECONSIDERATION CONTROLS AND DISPLAYS FMVSS 101-80

B.L.Cars Ltd., manufacturers of Jaguar, Triumph, Rover, M.G., Austin and Morris passenger cars and Land Rover and Range Rover M.P.V.'s petitions for reconsideration of FMVSS 101-80 - Controls and Displays under CFR 553.35.

We wish to adopt common specifications to satisfy the requirements of FMVSS 101-80 and EEC Directive 78/316 for the identification of controls and displays, and we find this is not possible with the two Regulations as currently written. We therefore request that FMVSS 101-80 be amended in the following respects to enable common specifications to be arrived at.

1. Amend Table 1, Column 3 by substituting for symbol shown in the line titled "Headlamps and Tail lamps" the symbol shown in ISO 2575/111-1975 for Master Lighting Switch, namely

if Separate Switch (Illegible Words)

Alternatively add the ISO symbol as an option.

2. Amend Table 1, Column 3 by adding in the line titled "Manual Choke" the symbol shown in ISO 2575/11-1975 for Choke.

3. Amend Table 2, Column 3 by adding in the line titled "Brake System" the symbol shown in ISO 2575/DAD 2 for Brake Failure.

These three amendments would be a step towards the accomplishment of the objective of the Notice published on 21st October, 1976 to identify these controls and displays with specified symbols which

(Graphics omitted) are internationally standardised. It is anticipated that the Brake System symbol will be adopted by ISO before the effective date of FMVSS 101-80; it has already been adopted by EEC and is under consideration by ECE.

An additional advantage would be to remove the anomaly present in FMVSS 101-80 which specifies the same symbol for two different functions namely Headlamps and Tail lamps control and High Beam telltale.

The preamble to FMVSS 101-80 says that some existing ISO symbols are not included in the final rule due to the fact that additional data are needed on their recognisability. The symbols we have requested to be adopted were produced by ISO in working parties in which representatives from the U.S.A. were engaged and these were the symbols which were considered by these working parties to be the most suitable for the purpose. We believe that there is now no better way to obtain universal recognition of these symbols than their adoption on vehicles in use in the U.S.A. and the rest of the world.

We request that this Petition be given urgent consideration because we have to act quickly to achieve the requirements by the effective date.

(Graphics omitted)

C. J. Goode Chief Engineer Vehicle Safety.

ID: nht79-1.45

DATE: 03/13/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Subaru of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your letter of October 17, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls, and Displays. You asked whether placing the turn signal symbol on the turn signal switch handle so that the arrows are vertical would comply with the standard.

The answer is no. Section 5.2.1 requires that the turn signal symbol appear preceptually upright to the driver. The purpose of that requirement is to ensure quick and accurate identification of the vehicle controls. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle.

SINCERELY,

OF AMAERICA, Inc.

October 17, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Re: @ 571.101 101-80

Dear Sir:

Fuji Heavy Industries Ltd, the manufacturer of Subaru motor vehicles, is working on their 1980 Model Year car lines for the U.S. market. Last week via telephone we contacted NHTSA's Mr. John Carson for an opinion about the identification symbol markings which will be required on our turn signal switch. Mr. Carson informed us that we are not the only auto manufacturer to inquire about vertical arrows but that we should write for an interpretation.

Fuji plans to identify their turn signal switch handle by using arrows as shown in Table One of the standard, but plans to have the arrows in a vertical mode rather than horizontal. If we (FHI) do display the "arrows" in a vertical axis will our symbol be in compliance?

John Cordner Technical Assistant Product Compliance

CC: FUJI HEAVY INDUSTRIES LTD; FUJI LIAISON OFC.

ID: nht79-1.46

DATE: 03/13/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Subaru of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your September 12, 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:

1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its "no problem" model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.

2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement in section 5.2.3 that the display symbol appear preceptually upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.

SINCERELY,

(Graphics omitted)

September 12, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Mr. Levin:

Subaru is designing a new instrument, monitor panel for future U.S. vehicle application. We are concerned about its compliance to the new FMVSS, SS101-80.

The new monitor panel will have a white lined symbol of a car, the front of the car will be at the top of the drawing. It will be on a dark green background. Telltale symbols and descriptive words will be within and around the car drawing as representative of functions or mal-function conditions. To identify a special condition a light-emitting devise will illuminate a symbol or symbol and words. At this time we request your approval on two issues as addressed below.

1. When the Subaru is being driven in daylight and there are no problems to cause any of the telltale devises to be illuminated, only the white outline of a car is visible. Our prototype monitor is shown in the enclosed photos. Photo "A" is representative of a "no problem" condition in daylight; is it in compliance to Standard 101-80?

2. We would like to display the high beam symbol and telltale in a different position than the standard, specifically, 90 degrees clockwise. We feel the repositioning of the high beam symbol will be more representative to the car outline with the head-lamps pointing ahead rather than to the left. The lamp to display a high beam "on" condition will be the color blue. Our photo "C" and diagram "E" demonstrates what we plan to do, particularly in regard to a high beam in "use" condition.

Does the above conform to FMVSS 101-80?

Paul Utans Assoc. Vice President Product Compliance

(Graphics omitted)

ID: nht79-1.47

DATE: 10/22/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mack Trucks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your letter of July 19, 1979, which requested an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You asked whether placing the turn signal symbol on the turn signal control shown in your illustration so that the arrows are vertical would comply with the standard.

The answer is no. Section 5.2.1 of the standard requires that the turn signal symbol appear perceptually upright to the driver. The purpose of that requirement is to ensure quick and accurate indentification of the vehicle controls. The upright position of a symbol is determined by referring to column 3 of Table 1 of Safety Standard 101-80. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle.

Since the symbols required by Safety Standard 101-80 were selected in order to facilitate international standardization and harmonization, it is important that they not be significantly altered from one vehicle to another. This is particularly important in order to ensure that drivers become familiar with the meaning of various symbols including the turn signal symbol.

However, Safety Standard 101-80 does permit manufacturers to supplement the symbols designated in Table 1 of the standard with additional words or symbols for the purpose of clarity. Therefore, nothing in the standard would prevent your company from adding additional symbols, such as curved thinner arrows next to the turn signal symbol, to indicate mode of operation.

SINCERELY,

9/11/79 - SECOND REQUEST

MACK TRUCKS, INC.

July 19, 1979

Administrator, National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Sir:

Subject: Request for Interpretation Turn Signal Control Identification FMVSS 101-80, Controls and Displays

Mack Trucks, Inc. will be introducing a new truck model later this year. The vehicle has been designed to comply with the current requirements of FMVSS 101-80, Controls and Displays. The attached photograph illustrates the instrument panel layout in a prototype vehicle. Since this vehicle is assembled in France, several features differ from current U.S. vehicle designs.

The turn signal control is located on the instrument panel to the lower left of the speedometer. This is a two function control in that horizontal movement switches the headlamps from low to high beam, while vertical movement activates the turn signals.

FMVSS 101-80 requires that this turn signal control be identified by a specified symbol and that the symbol appear perceptually upright to the driver. As we interpret the regulation, the symbol must be rotated 90 degrees from the position shown in the photograph in order to comply with the requirement. However, we feel that this could be confusing because the operation of the turn signal control is vertical. Although we realize that the symbol is there to indicate the function, not the operation, we question whether a driver will understand what the symbol indicates. We believe it is more appropriate to orient the symbol as shown in the photograph so as to reduce the possibility of confusion. (Note: Please disregard the headlamp symbol next to the turn signal symbol on the control since it will not be there on production vehicles.)

We would appreciate your comments and/or recommendations on the orientation of the turn signal symbol as soon as possible since production of these vehicles is scheduled to begin September 1, 1979.

Thomas F. Brown Executive Engineer-Vehicle Regulations and Standards

ATTACH.

bcc: L. F. DONNELLY; L. F. KASACZUN; E. PASCUAL; S. ROBSON; C. D. TREXLER

(Graphics omitted)

(Graphics omitted)

ID: nht79-1.48

DATE: 04/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Subaru of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 26, 1979, requesting our interpretation of whether the turn signal identification symbol which you propose meets the requirements of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. The answer is yes. As long as the turn signal symbol is displayed in the horizontal mode, as shown in Table 1, it will comply with the standard. Small additional arrows that will not be confused with the turn signal symbol may be incorporated to indicate movement of the control. Your thin vertical arrows do not appear to pose any possibility of causing such confusion.

Sincerely,

ATTACH.

SABARU OF AMERICA, Inc.

March 26, 1979

Our Ref. No. 039-79C

Office of Chief Counsel -- National Highway Traffic Safety Administration, U.S. Dept. of Transportation

Gentlemen:

We request your approval of our interpretation of FMVSS 101-80, Controls and Displays, as it applies to turn signal switch identification.

For 1980 model year Subaru proposes to place identifying arrows in the horizontal mode. We also propose to have small arrows in the vertical axis to denote the direction of movement necessary to activate the turn signal switch. From the enclosed sketch you will note that the horizontal arrows are the predominant ones.

Due to production lead time problems, response at your earliest convenience will be greatly appreciated.

Sincerely,

Paul Utans -- Associate Vice President, Product Compliance

Enc.

cc: Fuji Heavy Industries, Ltd.; Fuji Liaison Office (Graphics omitted)

ID: nht79-1.49

DATE: 12/14/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Automobile Importers of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your October 29, 1979, request for an interpretation of the Federal motor vehicle safety standards. You asked whether vehicles equipped with space-saver spare tires must be tested for compliance with Federal motor vehicle safety standards with that spare tire actually used as one of the four tires mounted on the vehicle during the tests. Our interpretation is that the spare tire need not be used during those tests.

This agency does not currently require that a motor vehicle be equipped with a spare tire. If a spare tire is included with the vehicle, it must, of course, comply with all standards applicable to tires.

ID: nht79-1.5

DATE: 11/29/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Honorable S. I. Hayakawa United States Senate Washington, D.C. 20510

Dear Senator Hayakawa:

This responds to your October 25, 1979, letter enclosing correspondence from your constituent Mr. Morrill N. Farr asking about the agency's air brake standard. Mr. Farr also asked about the highway use tax. We understand that the Federal Highway Administration will respond to you directly with an answer to that question.

With respect to the air brake standard, Mr. Farr asked whether the Government would reimburse him for a portion of the costs of installing the no lockup portion of his air brake system. Mr. Farr stated that a court has held the no lockup requirement of the air brake standard invalid, and accordingly, the Government should reimburse vehicle owners for the installation of no lockup systems that have been proven to be faulty.

The court in PACCAR v. The National Highway Traffic Safety Administration, 573 F.2d 632 (9th Cir. 1978) cert. den'd 439 U.S. 862 (October 2, 1978), stated that the no lockup portions of the standard were invalid because some of the systems constructed in accordance with the requirements were unreliable. The court also indicated that a proper no lockup device could substantially improve the safety of vehicles. Our air brake standard does not specify a particular design or construction of brake system. It is a performance standard, and manufacturers are free to choose any design or construction that complies with the performance requirements. The fact that some manufacturers chose faulty systems is unfortunate. If the system on Mr. Farr's truck is faulty, his remedy lies with the manufacturers of the truck and the system, not with the Government.

This agency has attempted over the past several years to address the problem of faulty systems by initiating several investigations under the statutory provisions requiring manufacturers to recall and remedy defective vehicles and equipment. Those investigations contributed to the decisions of a number of manufacturers to conduct recalls.

Sincerely,

Frank Berndt Chief Counsel

Enclosure Constituent's Correspondence

October 25, 1979

Department of Transportation Congressional-Liaison 400 Seventh St. SW Washington, D.C. 20590

Gentlemen:

Enclosed is a copy of correspondence I received from Mr. Morrill Farr. I would appreciate any information you could provide regarding this matter.

Please forward your reply, in duplicate, to the attention of my staff assistant, Samuel R. Buck, Room 6217, Dirksen Senate Office Building, Washington, D.C. 20510.

Sincerely,

S. I. Hayakawa

SIH/pw Enclosure

ID: nht79-1.50

DATE: 11/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyo Kogyo U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your October 19, 1979, request for an interpretation of the requirements of Federal Motor Vehicle Safety Standard No. 110 and 49 CFR Part 575. Specifically, you inquired if it is permissible for Mazda to place information concerning the 185SR13 tire size on the tire placard, as required by section 4.3(d) of Standard No. 110, and in the consumer information booklet, as required by 49 CFR @ 575.102(c)(2), for vehicles which may have 185HR13 tires installed by dealers at a customer's request. This would be permissible.

A 185SR13 tire and a 185HR13 tire are the same size and have the same load-carrying capacity. The "S" and "H" only denote different high-speed capabilities for what are, otherwise, identical tires.

This agency requires the manufacturer to list recommended tire sizes on the tire placard and in the consumer information booklet for two reasons. First, the information is required to ensure that any replacement tires installed on the vehicle will be a proper size for the rims mounted on that vehicle. Second, the information helps to ensure that the tires installed on the vehicle will have sufficient load-carrying capacity to be used safely on that particular vehicle. Neither of these safety concerns would be frustrated by a manufacturer putting information on the placard and in the booklet about a tire with a lower speed rating. Therefore, your proposed plan would not violate any of our consumer information regulations.

Sincerely,

ATTACH.

October 19, 1979

Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir,

RE: Request for Interpretation on MVSS 110 & Part 575

MVSS 110 Sec. 4.3 (d) requires the vehicle manufacturer's recommended tire size designation on the tire placard and also Sec. 575.102 (c)(2) requires recommended tire size designations in the consumer information booklet. One of our MAZDA models has 185SR13 as the standard tires. Currently, we are considering 185HR13 as a dealer option because some customers want a higher performance tire on their cars. We do not believe that we should put 185HR13 as the recommended tire on the tire placard, for it is a higher performance than 185SR13 and it is not installed at our factory. Please grant us your interpretation.

Your earliest response would be highly appreciated.

Sincerely yours,

M. Ogata -- Branch Manager, TOYO KOGYO U.S.A. OFFICE

ID: nht79-1.6

DATE: 12/27/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Manning Equipment, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

In reply refer to: NOA-30

Mr. Denis Urban Manning Equipment, Inc. P.O. Box 23229 Louisville, Kentucky 40223

Dear Mr. Urban:

This responds to the questions raised in your December 5, 1979, conversation with Roger Tilton of my staff concerning the application of Federal safety standards to devices designed to aid the handicapped. In your conversation, you indicated that you will manufacture some devices that enable the handicapped to operate their own vehicles. These would be sold by you to individuals and installed in either new or used vehicles. You also will install lifts in vehicles.

The agency has no specific safety standards applicable to handicapped control devices or other devices designed to aid the handicapped. Therefore, we have no special guidelines that you must follow in constructing these devices. However, other Federal agencies, such as the Veterans Administration, have guidelines for such devices and we suggest that you comply with those guidelines.

The agency requires new vehicles to comply with all applicable safety standards. Accordingly, if you manufacture and install handicapped devices in new vehicles, those vehicles should comply with the standards. However, the agency has long realized that, in the instance of handicapped driver controls, it may be difficult to comply with some safety standards, particularly Standard No. 124, Accelerator Control Systems (copy enclosed). As a result of compliance problems and the need for these devices to promote the mobility of the handicapped, the agency has stated that it will not enforce standards whose compliance may be impaired as a result of the installation of handicapped driver control devices. Nonetheless, the agency encourages manufacturers to try to comply with all of the safety standards.

The compliance of vehicles with the safety standards, however, should not be affected by the installation of lifts. Many companies now install lifts in regular vans and in school buses. In all instances the compliance of the vehicle with the safety standards is maintained. Therefore, the agency will not allow any noncompliances to result from the installation of lifts in vehicles.

For used vehicles that you modify by the addition of devices to aid the handicapped, you need not ensure that the vehicles comply with all safety standards. You should not render inoperative the compliance of the vehicle with the safety standards, however. As in the case of new vehicles, if the addition of handicapped driver controls interferes with the compliance of the vehicle with the safety standards, the agency would not enforce the noncompliance.

Sincerely,

Frank Berndt Chief Counsel

Enclosure