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Interpretation ID: 1982-3.5

TYPE: INTERPRETATION-NHTSA

DATE: 09/17/82 EST

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Nissan Motor Co. Ltd. -- Shizuo Suzuki (Washington, D.C.)

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your request for an interpretation concerning Standard No. 101, Controls and Displays. You asked several questions concerning informational readout displays. The answers to your questions are as follows.

1. If one type of information is displayed by an electro illuminating device such as a light-emitting diode, can I define this as an IRD?

The answer to this question is yes. Section S4 of Standard No. 101 defines informational readout display as "a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed." [Emphasis added.] Thus, the type of system you describe comes within Standard No. 101's definition of informational readout display. In reference to the specific wording of your question, I would note that it is the definition in the standard, rather than a particular characterization by the manufacturer, that is determinative as to whether a display is an informational readout display.

2. Do you think that the description "other electro illuminating device" includes normal electric bulbs?

The answer to this question is no. The requirements applicable to informational readout displays are an exception to the usual requirements for displays, which ordinarily use normal electric bulbs. The preamble to the final rule establishing the requirements of the present Standard No. 101 explained that the reason for the exception was to "permit the continued development of informational readout displays." 43 FR 27541, June 26, 1978. This was necessary since current technology does not enable manufacturers to produce informational readout displays which can exhibit symbols (as opposed to words) or certain colors. Thus, while section S5.2.3 of Standard No. 101 makes the use of certain symbols and colors mandatory for traditional displays, the use of symbols and colors is optional for informational readout displays.

If "other electro illuminating device" was interpreted to include normal electric bulbs, traditional displays would come within the definition of informational readout display. Such an interpretation would render meaningless Standard No. 101's requirements for the mandatory use of certain symbols and colors for displays. It is thus clear that the term "other electro illuminating device" does not include normal electric bulbs. Rather, the term was included within the definition of informational readout display, along with light-emitting diodes and liquid crystals, to avoid preventing the use of new electronic technology other than light-emitting diodes and liquid crystals.

Your third and fourth questions both contemplate that the answer to your second question is yes, rather than no. In reference to your question as to why the agency amended Standard No. 101 to permit the use of green as an alternative to blue or blue-green for the headlamp high beam telltale, the reason is that the agency does not interpret the standard's definition of informational readout display to include a mere colored light using light-emitting diode technology. To be an informational readout display, it must include information in the form of words or symbols. Since such a colored light is not an informational readout display, it must meet the color requirements of Standard No. 101. On February 1, 1982, the agency published a notice in the Federal Register (47 FR 4541) which proposed, among other things, an interpretive amendment to the definition of informational readout display to make that point clear. We have enclosed a copy of that notice for your convenience.

Your fourth question suggests that the definition of informational readout display should be interpreted to include only displays providing more than one type of information. As explained in the answer to your first question, such an interpretation would be inconsistent with the wording of the standard's definition of informational readout display. The agency recognizes, however, that it is likely that most if not all informational readout displays will include more than one type of information, though it is possible that some manufacturers might use LED or similar technology for displays providing only one type. In any event, the agency is not aware of a need to revise the standard's requirements to exclude displays presenting only one type of information from the definition of informational readout display.

5. According to the current regulation, is it possible to integrate telltales with other instrument displays in an informational readout display?

The light intensity requirements of Standard No. 101 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section specifies that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.

We would note, however, that the notice of proposed rulemaking referred to above proposes an amendment to Standard No. 101 that would permit informational readout displays to be used as telltales. The agency is in the process of analyzing the comments received in response to that notice.

Our answer to your fifth question also covers your sixth question. I hope this fully responds to your inquiry.

ENC.

QUESTIONNAIRE CONCERNING "INFORMATIONAL READOUT DISPLAY"

1. If one type of information is displayed by an electro-illuminating device such as a light-emitting diode, can I define this as an IRD?

2. Do you think that the description "other electro illuminating device" includes normal electric bulbs?

3. If yes, we don't know the reason why NHTSA amended the regulation to permit manufacturers to use the color green as an alternative to blue for the headlamp high beam indicator. -- According to S5.3.2, the color of each telltale is designated. However, as as the color for the IRD is at the manufacturer's option, I think the color green can be used as the headlamp high beam indicator by the original regulation. Therefore, I think it not necessary to change the rule.

4. And if yes, we think that we can select a symbol or word designated in Table 2 for the IRD which shows one type of information (ex., Fuel Level), although normal displays have to use symbols designated in Table 2 (S.5.2.3.). -- I think if the definition of IRD is interpreted as more than one, we wouldn't have such a problem.

5. According to the current regulation, is it possible to integrate telltales with other instrument displays in an Informational Readout Display?

6. In this case, is it sufficient that the light intensities for the informational readout systems shall have at least two values prescribed in S.5.3.3? -- According to S.5.3.3, the light intensity of such telltales shall not be variable.