Interpretation ID: 1984-1.32

TYPE: INTERPRETATION-NHTSA

DATE: 04/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Nakaya Branch Manager Mazda (North America), Inc. Suite 462 23777 Greenfield Road Southfield, Michigan 48075

Dear Mr. Nakaya:

This responds to your letter of January 20, 1984, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked whether Mazda may modify the display of shift lever positions for vehicles equipped with automatic transmissions to delete the gear lever indicator. As explained below, FMVSS No. 102 does not permit the deletion of the gear position indicator.

You should be aware that the National Highway Traffic Safety Administration (NHTSA) does not pass approval on the compliance of any vehicle or equipment with a safety standard before the actual events that underlie certification. Under the Vehicle Safety Act, it is the manufacturer's responsibility to determine whether its vehicles and equipment comply with all applicable safety standards and regulations, and to certify its products in accordance with that determination. Therefore, the following statements only represent the agency's opinion based on the information provided in your letter.

Your letter states that Mazda automobiles with automatic transmissions currently display the gear lever sequence and identify the shift lever position of the automobile. Based on the information in your letter, the agency understands that you propose to modify the display in such a way that "the actual gear selection would not be indicated (as is the case of current manual transmissions)." The pattern of the gear positions would be embossed either on the instrument panel or on the shift lever handle.

Paragraph S3.2 of Federal Motor Vehicle Safety Standard No. 102 states that the "identification of shift lever positions of automatic transmissions...shall be permanently displayed in view of the driver." Emphasis added. 49 CFR S571.102. NHTSA interprets "position" to mean the position of the gears in relation to each other and the position that the driver has selected at the time of selection. Therefore, the display of a gear lever sequence and a gear position indicator is required for automobiles equipped with automatic transmissions.

You should note that FMVSS No. 101, Controls and Displays, also applies to the display of automatic gear positions. Paragraph S5 of the standard requires that, inter alia, each passenger car, multipurpose passenger vehicle, truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2 of the standard shall meet the requirements for the location, identification, and illumination of such display. Since "gear position" is listed under S5.1, and "Automatic Gear Position" is listed under Table 2, the requirements of FMVSS No. 101 apply to the display of shift lever positions in vehicles equipped with automatic transmissions.

Sincerely,

Frank Berndt Chief Counsel

January 20, 1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

RE: Interpretation of FMVSS 102 - Transmission Shift Lever Sequence, Starter Interlock and Transmission Braking Effect.

Dear Mr. Berndt:

In order to provide more flexibility in interior styling, Mazda is considering modifying the display of shift lever positions for automatic transmission equipped vehicles.

Currently, the display of gear positions is used simultaneously to indicate actual gear selection (located at the base of the shift lever on the center floor console). The modification would delete the display at the shift lever base and emboss the selection positions either on the instrument panel (visible to the driver) or on the shift lever handle. The gear sequence would remain the same as currently used and as described in Section 3.1.1. The actual gear selection would not be indicated (as is the case of current annual transmissions).

Mazda assumes this modification would still conform to the criteria described in Section 3.2 of Safety Standard 102. The result would be greater freedom in the area of occupant compartment design. Please comment on this assumption and any further relevent items.

Thank you.

Sincerely,

H. Nakaya Branch Manager

HN/ab