Interpretation ID: nht79-1.43

DATE: 01/12/79

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 27, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. Specifically, you asked whether it is permissible to use symbols for the parking lamp functions of the headlamp switch, in addition to the headlamp symbols required in Table I of the Standard.

The answer to your question is yes. Section 5 of the standard states that each passenger car "with any control listed in S5.1 or in column 1 of Table 1, . . . shall meet the requirements of this standard for the location, identification, and illumination of such control or display." Since no symbols or other designations are required under the standard for parking lamps where their control is not combined with that for headlamps or for "lamps-off" positions on controls, it is up to the manufacturer whether to label these additional functions and whether to use words or symbols. Footnote 2 of Table 1 of the standard does provide that a manufacturer must use the single headlamp symbol to designate several functions when clearance, identification, parking and/or side marker lamps are all controlled with the headlamp switch. This footnote was not intended to preclude additional symbols for these other functions, however. In fact, S5.2.1 provides that "additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity."

Regarding your drawings, clearance lamps are listed in paragraph S5.1 and in column 1 of Table 1 of the standard. Therefore, they must be identified by the symbols shown in column 3 of Table 1 or by the words "Clearance Lamps" or "Cl Lps". The "parking right and left" symbol shown on the drawing submitted with your letter would not satisfy the requirements for clearance-lamp designations. However, the symbol labeled "Clearance Lamps" that appears on the drawings which Mr. Gebhard M. Hespeler and Mr. Craig Jones submitted on December 20, 1978, would conform with the requirements. I have enclosed a copy of that drawing.

If you have any further questions, please do not hesitate to write.

SINCERELY,

November 27, 1978

National Highway Traffic Safety Administration Office of Chief Counsel

Re.: Request for Interpretation - FMVSS 101-80

Dear Madam or Sir:

Federal Motor Vehicle Standard 101-80, Controls and Displays, specifies symbols for identifying certain functions of hand-operated controls, but does not address the parking lamp function of the headlamp switch other than the reference contained in Footnote 2 Table I. We suspect this footnote statement is to simplify requirements for providing symbols on those switches, all of whose functional positions cannot readily be identified, such as push-pull switches. An interpretation is therefore requested as to whether or not it is permissable to use additional symbols for the parking lamp functions in addition to the headlamp symbols required in Table I of this standard. An example of such headlamp switch markings is shown in the attached drawing. This rotary switch has the following corresponding functions:

Full counter-clockwise; parking lamps, left-hand side of vehicle, ignition off.

Next position clockwise; parking lamps, right-hand side of vehicle, ignition off.

Vertical/middle position: all lamps off.

Next position clockwise; parking lamps and side marker lamps left and right, - ignition on or off.

Full clockwise; headlamps, parking and side marker lamps.

We would appreciate receiving your interpretation of this standard at your earliest convenience. Do not hesitate to contact this office should you require further information on the switch described.

HEINZ W. GERTH

Request for Interpretation - FMVSS 101-80

Mercedes-Benz of North America, Inc.

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