Interpretation ID: nht79-1.44

DATE: 04/06/79

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Leyland Cars

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your July 17, 1978, letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.

You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.

You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those item. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.

SINCERELY,

Engineering and Product Planning Division

British Leyland UK Limited

The Administrator, National Highway Traffic Safety Administration,

JULY 17, 1978 Dear Madam,

PETITION FOR RECONSIDERATION CONTROLS AND DISPLAYS FMVSS 101-80

B.L.Cars Ltd., manufacturers of Jaguar, Triumph, Rover, M.G., Austin and Morris passenger cars and Land Rover and Range Rover M.P.V.'s petitions for reconsideration of FMVSS 101-80 - Controls and Displays under CFR 553.35.

We wish to adopt common specifications to satisfy the requirements of FMVSS 101-80 and EEC Directive 78/316 for the identification of controls and displays, and we find this is not possible with the two Regulations as currently written. We therefore request that FMVSS 101-80 be amended in the following respects to enable common specifications to be arrived at.

1. Amend Table 1, Column 3 by substituting for symbol shown in the line titled "Headlamps and Tail lamps" the symbol shown in ISO 2575/111-1975 for Master Lighting Switch, namely

if Separate Switch (Illegible Words)

Alternatively add the ISO symbol as an option.

2. Amend Table 1, Column 3 by adding in the line titled "Manual Choke" the symbol shown in ISO 2575/11-1975 for Choke.

3. Amend Table 2, Column 3 by adding in the line titled "Brake System" the symbol shown in ISO 2575/DAD 2 for Brake Failure.

These three amendments would be a step towards the accomplishment of the objective of the Notice published on 21st October, 1976 to identify these controls and displays with specified symbols which

(Graphics omitted) are internationally standardised. It is anticipated that the Brake System symbol will be adopted by ISO before the effective date of FMVSS 101-80; it has already been adopted by EEC and is under consideration by ECE.

An additional advantage would be to remove the anomaly present in FMVSS 101-80 which specifies the same symbol for two different functions namely Headlamps and Tail lamps control and High Beam telltale.

The preamble to FMVSS 101-80 says that some existing ISO symbols are not included in the final rule due to the fact that additional data are needed on their recognisability. The symbols we have requested to be adopted were produced by ISO in working parties in which representatives from the U.S.A. were engaged and these were the symbols which were considered by these working parties to be the most suitable for the purpose. We believe that there is now no better way to obtain universal recognition of these symbols than their adoption on vehicles in use in the U.S.A. and the rest of the world.

We request that this Petition be given urgent consideration because we have to act quickly to achieve the requirements by the effective date.

(Graphics omitted)

C. J. Goode Chief Engineer Vehicle Safety.