Interpretation ID: nht74-1.10

DATE: 10/04/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 11, 1974 asking for an interpretation of paragraph S5.3.5 of Standard No. 105-75. You indicate that a prospective Nissan design uses a common indicator lamp to show both loss of fluid pressure and low brake fluid level. You ask if the indicator lamp lens may be labeled "Brake Failure."

The answer is no. If separate indicator lamps are used, Standard No. 105-75 allows words in addition to "Brake" to indicate the specific area where a problem may exist, e.g. an indicator lamp may be labelled "Brake fluid" to indicate a low level of fluid. However, if a lamp indicates more than one type of condition, paragraph S5.3.5 specifies that only a single word, "Brake," may be used. This alerts a driver in a general way that a problem exists somewhere in the brake system. We think the restriction of S5.3.5 preferable for most circumstances. In the configuration you propose for example, the word "Failure" would not accurately describe a low level of brake fluid.

We appreciate your continued interest in vehicle safety.

Yours truly,

ATTACH.

September 11, 1974

Richard B. Dyson -- Acting Chief Council, National Highway Traffic Safety Administration

Dear Mr. Dyson:

This is to ask your interpretation of S.5.3.5, indicator lamp requirement of MVSS 105 - 1975, which states:

"If separate indicator lamps are used for one or more of the various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure', 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used."

As I explained to Mr. Vinson on the phone, Nissan's 1976 model will be equipped with two sensors, brake fluid level sensor and pressure loss sensor (if one of the two sensors or both operate, the indicator lamp turns on). Therefore, since we cannot use either the word "Brake Pressure" or "Brake Fluid" as requested in the standard, we would like to use the word "Brake Failure" instead.

Would you kindly advise us as to whether or not this word "Brake Failure" is acceptable; and if not, please recommend a suitable word for our use. Your cooperation would be greatly appreciated.

Thank you.

Very truly yours,

NISSAN MOTOR COMPANY, LTD.; Tatsuo Kato -- Staff, Safety