Interpretation ID: nht79-1.42
DATE: 10/19/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Volkswagen of America
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. Specifically, you asked whether a "barely discernible" light on the headlamp control, which is activated when the ignition is turned to the "on" position, complies with the requirements of the standard. Under S5.3.3, "any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable . . . ." Since the light in question is not activated when the headlamps are activated, it need not meet the intensity requirements of S5.3.3.
SINCERELY,
VOLKSWAGEN OF AMERICA
JULY 27, 1979
Kathy Demeter Office of Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation
SUBJECT: Interpretation - FMVSS 101-80
Dear Kathy,
It is imperative that we obtain a response to the attached request for interpretation. We would appreciate its expeditious handling.
Charles F. Finn
ENC.
VOLKSWAGEN OF AMERICA
JUNE 26, 1979
Office of Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation
Subject: Interpretation - FMVSS 101-80
Gentlemen:
Volkswagen requests your concurrence of our interpretation of FMVSS 101-80, Controls and Displays as it applies to the headlamp control.
Presently, as a courtesy to the driver, Volkswagen provides a barely discernible light on the headlamp control. This light is activated when the ignition is turned to the "On" position. This facilitates finding the switch in the dark.
It is our interpretation that this light complies with the standard as specified in Sections S5.3.1 and S5.3.3 and therefore is not required to be variable.
John Carson and Nelson Erickson of the NHTSA, in phone conversations with a member of my staff, indicated that they thought Volkswagen's interpretation was correct and believed that there already was an interpretation rendered by the Chief Counsel's office on this matter. Volkswagen would be desirous of obtaining this document.
Response to this request at your earliest convenience will be greatly appreciated.
Dietmar K. Haenchen Administrator Vehicle Regulations