ID: nht79-1.4

DATE: 01/16/79

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

TO: R. D. Phillips

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Richard D. Phillips Attorney At Law P.O. Box 66 Ludowici, Georgia 31316

Dear Mr. Phillips:

This responds to your December 15, 1978, questions about the status of school buses subject to recall for antilock malfunction now that the "no lockup" requirement of Standard No. 121, Air Brake Systems, has been invalidated in the cases of trucks and trailers. You also ask whether the antilock systems in question must be reconnected, whether the vehicles would thereby be made more or less safe, and what the effect of continued disconnection might be on liability considerations.

I have enclosed the agency's official interpretation of the effect of the invalidation on the operational status of vehicles equipped with antilock. In the case of vehicles subject to recall, we stated that section 154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1414) mandates an "adequate repair," and that, in the NHTSA's view, the benefits of "no lockup" performance mandate the offer of repair and reconnection.

The letter also states that disconnection, consistent with regulations of other authorities and the instructions of the manufacturer, would not violate the Vehicle Safety Act. While the NHTSA finds that the repair would provide desirable "no lockup" performance, we are unable to counsel you on the Long County Board of Education's liability if the system were not reconnected.

Sincerely,

Original Signed By

Joseph J. Levin, Jr. Chief Counsel

Enclosure

ID: nht79-1.40

DATE: 08/21/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ford Motor Company

TITLE: FMVSR INTERPRETATION

TEXT:

AUG 21 1979 NOA-30

Mr. J. C. Eckhold, Director Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Eckhold:

This is in response to your letter of August 3, 1979, asking whether Ford may ship to distributors and dealers vehicles with bumper guards, needed for compliance with Part 581, Bumper Standard (49 CFR Part 581), placed inside the vehicles for installation prior to sale of the vehicles to consumers. You state that the bumper guards, which would be attached by dealers and others making use of pre-processed mounting holes in the vehicle bumpers, would reduce railroad car capacity, if installed prior to shipment. You also suggest that absence of reference in the Customs regulations (19 CFR Part 12) to readily attachable components needed to comply with regulations issued under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901), may lead to complications in the importation of vehicles prior to installation of readily attachable bumper components.

The National Highway Traffic Safety Administration has no objection to the shipment of vehicles with readily attachable bumper components stored in the vehicles for later installation, provided the components are attached before the vehicles are offered for sale to the first purchaser for purposes other than resale. Further, regulations governing importation of motor vehicles (19 CFR 12.80) apply only to compliance with Federal Motor vehicle safety standards, as set forth in 49 CFR Part 571, and the question of compliance with Part 581, therefore, should not arise.

Sincerely,

Frank Berndt Chief Counsel

August 3, 1979

Mr. Richard J. Hipolit, Esq. Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S. W. Washington, D. C. 20590

Dear Mr. Hipolit:

This is to request an interpretation of Part 581, Title 49, Code of Federal Regulations, as to readily attachable and detachable equipment that constitute portions of the bumper system on passenger cars subject to the "Phase II" requirements of Part 581 that become effective on and after September 1, 1979.

Unlike regulations issued under the National Traffic and Motor Vehicle Safety Act, Part 581 does not expressly provide that a vehicle which conforms to the criteria of the bumper standard with readily attachable equipment installed -- such as bumper guards --is deemed also to be in conformity when shipped with the readily attachable equipment placed in the vehicle for installation by dealers or others prior to the first retail sale (by means of designated, pre-processed installation points on the vehicle, e.g., bumper guard mounting holes pierced in the bumper).

A number of practical problems can be expected to arise in the absence of appropriate interpretation of Part 581 to deal with the realities of manufacture and distribution. As Mr. D. G. McGuigan informed you last week, Ford has determined, for example, that substantial and wasteful transportation complications can be avoided on one of its 1980 model passenger car lines by shipping front and rear bumper guards inside the vehicles, to be installed by dealers prior to retail sale. That situation involves both tariff restrictions and limitations on the capacity of tri-level rail cars. For 1979 models of the cars in question, shipped without bumper guards, each tri-level rail car can accommodate 18 vehicles. The same capacity would be available for 1980 models if bumper guards were not installed until the vehicles reached their final destinations. If bumper guards are installed at the factory, however, only 15 units could be carried on each rail car, and the resulting three unit reduction in carrying capacity would increase Ford's requirement for rail car use, I am informed, by approximately 151 rail cars per month.

Similarly, in view of the fact that imported cars may be transported to this country with readily attachable equipment placed inside the vehicle to help minimize transit damage on the high seas, we foresee the possibility of unintended complications also arising for imported vehicles if the readily attachable equipment issue is not dealt with. Part 12 of Title 19, the Customs Service regulation jointly developed by the Departments of Transportation and Treasury, expressly recognizes and deals with readily attachable equipment for Safety Act purposes, but there appears to be no parallel provision concerning regulations, such as Part 581, established under the Motor Vehicle Information and Cost Savings Act.

We believe that the requested interpretation is consistent with the intent and purposes of Part 581 and is in the public interest because it will serve to avoid economic waste in the manufacture and transport of passenger cars while preserving for retail purchasers the protection that the performance requirements of Part 581 are intended to provide. Because production of 1980 models are in the process of manufacture and shipments expected to begin in the next two weeks, we should appreciate this request receiving expedited attention.

Sincerely,

J. C. Eckhold Director Automotive Safety Office

ID: nht79-1.41

DATE: 08/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Porshe

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 25, 1979, requesting clarification of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. You asked whether the rear window defogger switch, which emits a dim light for control location and a brighter light upon activation, is considered a control or a telltale.

Although the switch might be regarded as a control, telltale, or both, it is regulated as a control insofar as its illumination is concerned. Therefore, its illumination must be continuously variable as specified in S5.3.3 of the standard.

S5.3.3 provides that

Each passenger car . . . manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car . . . with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.

The rear window defrosting and defogging system appears in the control list of S5.1 and in Table 1, but not in the display list of S5.1 or in Table 2. Therefore, the control illumination requirements of S5 apply to the defogging switch and the display illumination requirements do not.

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

SINCERELY,

UNITED STATES COMPLIANCE OFFICE

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Office of the Chief Counsel

May 25, 1979

Subject: PART 571, FMVSS 101-80, Docket 1-18, Notice 13 Control Location, Identification and Illumination

Dear Sirs:

In Table 1 of the above docket, the rear window defrosting and defogging system control shall be illuminated.

S 5.3.3 reads: "Light intensities for controls etc. and their identification shall be continously variable. . ."

In the same paragraph it reads: "The light intensity of each telltale shall not be variable and shall be such that, when activated, that telltale and its identification are visible to the driver under all daytime and nighttime conditions."

In one of our cars, the Porsche 928, the dashboard illumination and a dim light inside the rear window defogger switch are activated when the ignition is turned on. The dim light within the defogger switch is meant to help to locate this control. Upon activation of this switch the light intensity of the defogger switch is increased to show that the rear window defogger switch is in the "on" position. Both light intensities, dim to locate the control, and brighter for activation, are not variable.

Please clarify if w should consider the light in the rear window defogger switch a "telltale" or a "Control" and if we are in compliance with the 2 different light intensities.

We enclose 2 pictures from the owner's manual to show the location and activation of the switch.

Thank you in advance for your clarification.

Gerhard C. Waizmann

Enclosures omitted.

ID: nht79-1.42

DATE: 10/19/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. Specifically, you asked whether a "barely discernible" light on the headlamp control, which is activated when the ignition is turned to the "on" position, complies with the requirements of the standard. Under S5.3.3, "any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable . . . ." Since the light in question is not activated when the headlamps are activated, it need not meet the intensity requirements of S5.3.3.

SINCERELY,

VOLKSWAGEN OF AMERICA

JULY 27, 1979

Kathy Demeter Office of Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

SUBJECT: Interpretation - FMVSS 101-80

Dear Kathy,

It is imperative that we obtain a response to the attached request for interpretation. We would appreciate its expeditious handling.

Charles F. Finn

ENC.

VOLKSWAGEN OF AMERICA

JUNE 26, 1979

Office of Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Subject: Interpretation - FMVSS 101-80

Gentlemen:

Volkswagen requests your concurrence of our interpretation of FMVSS 101-80, Controls and Displays as it applies to the headlamp control.

Presently, as a courtesy to the driver, Volkswagen provides a barely discernible light on the headlamp control. This light is activated when the ignition is turned to the "On" position. This facilitates finding the switch in the dark.

It is our interpretation that this light complies with the standard as specified in Sections S5.3.1 and S5.3.3 and therefore is not required to be variable.

John Carson and Nelson Erickson of the NHTSA, in phone conversations with a member of my staff, indicated that they thought Volkswagen's interpretation was correct and believed that there already was an interpretation rendered by the Chief Counsel's office on this matter. Volkswagen would be desirous of obtaining this document.

Response to this request at your earliest convenience will be greatly appreciated.

Dietmar K. Haenchen Administrator Vehicle Regulations

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)