Interpretation ID: 1982-3.9
TYPE: INTERPRETATION-NHTSA
DATE: 10/14/82
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Isuzu Motors America, Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
FMVSS INTERPRETATION Mr. Koji Tokunaga Manager, Engineering Isuzu Motors America, Inc. 21415 Civic Center Drive Southfield, Michigan 48076
Dear Mr. Tokunaga:
This responds to your letter concerning Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock and Transmissions Braking Effect. You asked whether a 5-speed automatic transmission which you are considering producing meets the requirement of section S3.1.1 that a neutral position be located between forward drive and reverse drive positions.
By way of background information, I would point out that the agency does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. Therefore, the following statements only represent the agency's opinion based on the information provided in your letter.
In reference to the diagram enclosed with your letter, the relevant question is whether, in accordance with the above requirement, there is a neutral position between the HD (highway drive) and R (reverse) positions. As explained below, it is our opinion that the answer to that question is yes.
Your letter states that "the transmission is neutral whenever the shift lever is at any place on the horizontal line (including its left and right extreme ends) at the center of which the mark 'N' is shown." Further, your letter indicates that "the shift lever is spring-loaded to return to the center of the horizontal line ('N' position) whenever the lever is left free on that line."
In shifting between HD and R, the lever must cross the horizontal line. We understand that if the lever is merely held on the horizontal line at the crossing point, i.e., the extreme right, the transmission will be in neutral.
Further, we understand that if the lever is left free in that position, it will return to the center of the horizontal line where it will remain in neutral. Based on these two understandings, it is our opinion that the extreme right crossing point constitutes a neutral position between the HD and R positions.
Sincerely,
Frank Berndt Chief Counsel
DET82-134
May 18, 1982
Mr. George L. Parker Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington D.C. 20590
Dear Mr. Parker,
This letter is intended to seek your advice on the interpretation of the requirement in FMVSS 102 on the location of automatic transmission shift lever positions.
Show in the attached sheet is the shift lever pattern of a 5-speed automatic transmission we are planning to use on our passenger car. As far as you see on the pattern, it looks one can shift from "HD" (highway drive) to "R" or vice versa without passing a neutral position. But the fact is that the transmission is neutral whenever the shift lever is at any place on the horizontal line (including its left and right extreme ends) at the center of which the mark "N" is shown. Therefore, we think arrangement meets the requirement of FMVSS 102, S3.1.1 which says: "A neutral position shall be located between forward drive and reverse drive positions."
For additional information, the shift lever is spring-loaded to return to the center of the horizontal line ("N" position) whenever the lever is left free on that line. The lever can be moved from "HD" to "R" and vice versa at any time but a built-in transmission control unit works to prevent gear engagement unless the vehicle speed is suitable for the intended shift.
We would like to receive NHTSA's interpretation about the compliance of this system with FMVSS 102. Your prompt attention to this matter would be appreciated.
Sincerely yours,
Koji Tokunaga Manager, Engineering