Interpretation ID: nht79-2.16
DATE: 11/02/79
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Nissan Motor Co., Ltd.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Hisakazu Murakami Technical Representative - Safety Engineering Office of North America Nissan Motor Co., Ltd. 1919 Pennsylvania Ave., N.W., Suite 707 P.O. Box 57105 WashinSton, D.C. 20037
Dear Mr. Murakami:
This is in response to your letter of September 14, 1979, in which you asked about the applicability of the variable intensity illumination requirements of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays, to various components in your company's automobiles. You listed and identified these parts in Figure 1 of your letter which will refer to in answering your questions.
The variable intensity illumination requirements of section 5.3.3 of Safety Standard 101-80 are applicable to (1) "con- trols, gauges, and their identification, and to (2) any illumination that is provided in the passenger compartment when and only when the headlights are activated." As noted in section 5 of Safety Standard 101-80, the location identification, and illumination requirements are applicable only to passenger cars and other vehicles equipped with any control listed in section 5.1 or in column 1 of Table 1. The term "gauqe" is defined in Section 4 as a "display that is listed in section 5.1 or in Table 2 and is not a telltale."
Applying these criteria to the list of automobile components in your letter, I have concluded that none of the listed components, except the ordinary clock and the automatic gear position illumination lamp, are subject to the requirements of section 5.3.3 of Safety Standard 101-80. Since this result resolves the issues raised in Questions Q2.1 - Q2.5 of your letter, I have not addressed them in this response.
The components identified in your diagram by letters a - h (the room lamp, spot lamp, luggage room lamp, personal lamp, radio, foot lamp step lamp, and the luggage room lamp for hatchback vehicles) are not subject to the requirements of section 5.3.3. This is because they are not controls listed in section 5.1 or in column 1 of Table 1 of Safety Standard 101-80 and because they do not illuminate the passenger compartment when and only when the headlights are activated.
Similarly the glove box lamp and the console box lamp (items i and j) are not subject to section 5.3.3. They are not controls listed in Safety Standard 101-80 and they are not activated when and only when the headlights are activated since their activation requires both opening the box lids and switching on the headlights.
The ignition key illumination lamp (item k), which is not a control listed in Safety Standard 101-80, is activated when the light control switch is turned to the "small lights only" position (this activates the clearance clamps, identification lamps, and other exterior lamps other than the headlights.) When the switch is turned to the position that activates both, the small lights and the headlights, the key illumination lamp is deactivated. Consequently, the lamp is not activated when and only when the headlights are activated and is, therefore, not subject to the variable intensity illumination requirements.
You noted in conversation with Ms. Debra Weinner of my office that your company uses two types of clocks (item 1 in your letter) in its automobiles. One is an ordinary clock whose face is illuminated when and only when the headlights are activated. The requirements of section 5.3.5 would apply to the illumination of this type of clock.
The other clock used in your company's automobiles is a digital clock with a flourescent readout which shines with greater intensity during the day and with a lower intensity at night when the headlights are activated. Since this clock is not a control or a display listed in Safety Standard 101-80 and its illumination is not activated when and only when the headlamps are activated, the requirements of section 5.3.3 for continuously variable illumination are not applicable. Section 5.3.3 also provides that light intensity for informational readout systems shall have at least two values. The term "informational readout systems" which is not defined in Safety Standard 101-80 refers to the term "informational readout display," which is defined as "a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed." The term "display" includes only those displays listed in section 5.1 or in column 1 of Table 2 of the standard and these listings do not include a digital clock. Therefore, the digital clock would not be subject to the light intensity requirements for informational readout systems.
The automatic gear position illumination lamp (item m in your letter) is subject to the variable intensity illumination requirements of section 5.3.3. Although it is not a control (see preamble to Safety Standard 101-80, 43 FR 27541, June 26, 1978) this lamp is activated when and only when the headlights are activated.
In Question 2 of your letter, you asked for the definition of the terms "continuously variable" and "variable." The term "continuously variable" is defined in section 5.3.3(a) and (b) of Safety Standard 101-80. It is followed by a description of the two light intensities which must be provided for informational readout systems. The term "variable" appears in the next sentence in section 5.3.3 which states that:
"The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph.
The underlined words in the quoted sentence refer to the definition of "continuously variable" except in the case of informational readout displays where the words refer to illumination of two intensities.
If you have any further questions, I will be happy to answer them.
Sincerely,
Frank Berndt Chief Counsel
September 14, 1979
Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590
Dear Mr. Berndt:
Re FMVSS 101-80 - Controls and Displays I would like to take this opportunity to ask for your interpretation with regard to FMVSS No. 101-80 - Controls and Displays.
I would appreciate it if you could please answer the questions that I have attached.
Thank you for your usual fine cooperation.* CR Very truly yours,
NISSAN MOTOR CO., LTD.
Hisakazu Murakami Technical Representative Safety
HM:kb
Attachments Q-1 Generally speaking, would it be necessary for each one of items (a) to (m) in Figure-1 to meet the requirements of S 5.3.3?
Q-2 Assuming that your answer to Q-1 is "yes",
Q-2.1 Please explain the reason for your answer being "yes"
Q-2.2 Would the light intensity of (a) to (e), as shown in Figure-1, and having individual "On-Off" Manual Switches be considered variable?
Q-2.3 Would the light intensity of (f) Foot Lamp, (g) Step Lamp and (h) Luggage Room lamp, which light automatically only when doors are open, and not when they are closed, be considered variable?
Q-2.4 Would the light ingensity of (i) Glove Box Lamp and (j) Console Box Lamp, which are placed in their boxes and light only when the headlights are activated and their lids are open, be considered variable?
Q-2.5 Would the light intensity of (k) Ignition Key Illumination Lamp, which is placed near ignition key cylinder and lights only when clearance lamps, identification lamps and side marker lamps, etc. (other than headlights) are lit, be considered variable?
Q-2.6 Would the clock (1) with the flourescent display be considered to be the informational readout system?
Q-2.7 Assuming that your answers to Q-2.2 -Q-2.5 are "no", please explain the definition of the word "variable" and "not continuously variable".
Q-2.8 Would the light intensity of (m) Automatic Gear Position Illumination Lamp, which is placed on the floor-console box, be required to be variable, or continuously variable?
**INSERT** (a) Room (Dome) Lamp
(b) Spot Lamp (like one in airplane)
(c) Luggage Room for wagon vehicle -
(d) Personal Lamp for rear seat passengers
(e) Radio
(f) Foot Lamp
(g) Step Lamp
(h) Luggage Room Lamp for hatchback vehicle
(i) Glove Box Lamp
(j) Console Box Lamp
(k) Ignition Key Illumination Lamp (l) Clock
(l) Clock
(m) Automatic Gear Position Illumination Lamp -
FIGURE - 1