Interpretation ID: nht79-1.45

DATE: 03/13/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Subaru of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in responding to your letter of October 17, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls, and Displays. You asked whether placing the turn signal symbol on the turn signal switch handle so that the arrows are vertical would comply with the standard.

The answer is no. Section 5.2.1 requires that the turn signal symbol appear preceptually upright to the driver. The purpose of that requirement is to ensure quick and accurate identification of the vehicle controls. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle.

SINCERELY,

OF AMAERICA, Inc.

October 17, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Re: @ 571.101 101-80

Dear Sir:

Fuji Heavy Industries Ltd, the manufacturer of Subaru motor vehicles, is working on their 1980 Model Year car lines for the U.S. market. Last week via telephone we contacted NHTSA's Mr. John Carson for an opinion about the identification symbol markings which will be required on our turn signal switch. Mr. Carson informed us that we are not the only auto manufacturer to inquire about vertical arrows but that we should write for an interpretation.

Fuji plans to identify their turn signal switch handle by using arrows as shown in Table One of the standard, but plans to have the arrows in a vertical mode rather than horizontal. If we (FHI) do display the "arrows" in a vertical axis will our symbol be in compliance?

John Cordner Technical Assistant Product Compliance

CC: FUJI HEAVY INDUSTRIES LTD; FUJI LIAISON OFC.