Interpretation ID: nht79-1.46

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 September 12, 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:

1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its "no problem" model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.

2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement in section 5.2.3 that the display symbol appear preceptually upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.

SINCERELY,

(Graphics omitted)

September 12, 1978

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

Dear Mr. Levin:

Subaru is designing a new instrument, monitor panel for future U.S. vehicle application. We are concerned about its compliance to the new FMVSS, SS101-80.

The new monitor panel will have a white lined symbol of a car, the front of the car will be at the top of the drawing. It will be on a dark green background. Telltale symbols and descriptive words will be within and around the car drawing as representative of functions or mal-function conditions. To identify a special condition a light-emitting devise will illuminate a symbol or symbol and words. At this time we request your approval on two issues as addressed below.

1. When the Subaru is being driven in daylight and there are no problems to cause any of the telltale devises to be illuminated, only the white outline of a car is visible. Our prototype monitor is shown in the enclosed photos. Photo "A" is representative of a "no problem" condition in daylight; is it in compliance to Standard 101-80?

2. We would like to display the high beam symbol and telltale in a different position than the standard, specifically, 90 degrees clockwise. We feel the repositioning of the high beam symbol will be more representative to the car outline with the head-lamps pointing ahead rather than to the left. The lamp to display a high beam "on" condition will be the color blue. Our photo "C" and diagram "E" demonstrates what we plan to do, particularly in regard to a high beam in "use" condition.

Does the above conform to FMVSS 101-80?

Paul Utans Assoc. Vice President Product Compliance

(Graphics omitted)