Interpretation ID: aiam3889
Regional Sales Manager
Isuzu Diesel of North America
41169 Vincenti Court
Novi
MI 48050;
Dear Mr. Martz: This responds to your letter asking about identification requirement applicable to water temperature, oil pressure and alternator instruments on bread delivery trucks. You asked whether the symbols specified by Standard No. 101, *Controls and Displays*, are required for such trucks and, if so, whether it is permissible to use transparent decals with the proper symbols on the lenses. You also asked whether waivers can be issued. The answers to your questions are provided below.; Federal Motor Vehicle Safety Standard No. 101, *Controls and Displays* specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Water temperature, oil pressure and alternator instruments are displays. While the standard's requirements for controls apply to all trucks, the standard's requirements for displays are only applicable to trucks with a gross vehicles weight rating of less than 10,000 pounds. See section S5.; Assuming that your bread trucks do have a gross vehicle weight ratin of less than 10,000 pounds, the instruments must be identified by the symbols specified by Standard No. 101. Section S.2.3 provides in relevant part:; >>>Except for informational readout displays, any display locate within the passenger compartment and listed in column 1 of Table 2 that has a symbol designated in column 4, shall be identified by that symbol. Such display may, in addition be identified by the word or abbreviation shown in column 3.... Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification required or permitted by this section shall be placed on or adjacent to the display that it identifies. The identification of any display shall, under the conditions of S6, be visible to the driver and appear to the driver perceptually upright.<<<; The displays described by your letter are conventional gauges rathe than informational readout displays. (Informational readout displays are defined by the standard to be displays using light-emitting diodes, liquid crystals, or other elector illuminating devices where one or more than one type of information may be displayed.) Table 2 specifies symbols for, among other displays, oil pressure gauges, coolant temperature gauges, and electrical charge gauges. Therefore, under S5.2.3, the displays must be identified by the specified symbols.; Standard No. 101 does not specify the nature of the material to be use in identifying displays, i.e., paint, decals, etc. Therefore, it is permissible to use decals.; You also asked whether waivers can be issued. In a telephon conversation with Edward Glancy of this office, you indicated that some trucks have been produced using words rather than symbols to identify the gauges discussed above. 49 CFR Part 556 sets forth procedures for petitioning for exemption from the notification and remedy requirements of the National Traffic and Motor Vehicle Safety Act due to the inconsequentiality of a noncompliance with a safety standard as it relates to motor vehicle safety. I have enclosed a copy of Part 556 for you convenience, as well as a copy of Standard No. 101.; Sincerely, Frank Berndt, Chief Counsel