Interpretation ID: nht71-1.3

DATE: 06/22/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Toyota Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 2, 1971, requesting clarification of S4.3 of FMVSS No. 110, which requires a placard containing specified information to be "permanently affixed to the glove compartment door or an equally accessible location." Your letter lists seven locations on the vehicle (steering column, lower instrument panel pad or knee pad forward of the front seat occupants, sun visor, inside panel surface of the driver's door, door-latch post next to the driver's seat, door edge that meets the door-latch post next to the driver's seat, and door edge that meets the hinge pillar next to the driver's seat) and asks whether each would be considered an "equally accessible location" under the standard.

The phrase "glove compartment door or equally accessible location" is intended to require the placard to be affixed to a location where, like the glove compartment door, it can not only be easily referred to, but where it will also be relatively free from exposure to substances that may destroy it or render it illegible. With reference to your list of seven locations, we cannot determine without the specific configuration of the components involved whether placing the placard at any point on the component will meet the requirement. However, we believe the placard could be placed at some point on each of these components or locations so that the requirements of the standard would be met.

Please let us know if you have further questions.

Sincerely,

June 2, 1971

Douglas W. Toms Acting Administrator National Highway Traffic Safety Administration

Dear Mr. Toms:

This is to request the interpretation of the words "equal accessible" in S4.3 placard of Federal Motor Vehicle Safety Standard No. 110.

S4.3 specifies "A placard, permanently affixed to the glove compartment door or an equally accessible location, shall display the -----." In meeting this requirement, the design of the instrument panel or the glove compartment door some times necessitates us to seek the location for the placard somewhere other than the glove compartment door. We would understand that the places such as the following are considered to be "equally accessible locations".

1) Steering column 2) Lower instrument panel pad or knee pad foward of the front seat occupants

3) Sun visor

4) Inside panel surface of the driver's door

5) Door-latch post next to the driver's seat

6) Door edge that meets the door-latch post next to the driver's seat

7) Door edge that meets the hinge pillar next to the driver's seat

We would like to ask your interpretation or view toward our understanding of this matter.

Thank you for your cooperation.

Sincerely,

TOYOTA MOTOR CO., LTD. --

Kunitaka Suzuki for Keitaro Nakajima, General Manager