Interpretation ID: nht80-2.18

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Stewart-Warner Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. R. W. Strauss Stewart-Warner Corporation Washington Offices 425 - 13th Street, N.W. Washington, D.C. 20004

Dear Mr. Strauss:

This responds to your letter of January 24, 1980, which requested approval of an odometer design developed by Stewart-Warner in order to comply with section 4.2.3 of Federal Motor Vehicle Safety Standard No. 127, Speedometers and Odometers. Based on our understanding of the information that you have supplied, it appears that Stewart-Warner's design, which incorporates either a seventh wheel or a sixth wheel (for odometers which do not register tenths of a mile) printed with a series of the numeral 1 to indicate that the vehicle has traveled in excess of 99,999 miles or kilometers, would comply with section 4.2.3 of Safety Standard No. 127.

Section 4.2.3 of Safety Standard No. 127 requires that each odometer other than a motorcycle odometer:

"clearly indicate to the vehicle driver by a sixth wheel or digit registering whole miles or kilometers or by a permanent means such as inking, when the number of whole miles or whole kilometers, as appropriate, has exceeded either at the manufacturer's option 89,999 or 99,999."

Stewart-Warner's design, as described in your letter, would register whole miles or kilometers from 100,000 to 199,999. Once the vehicle in which the odometer was installed had traveled 200,000 miles or kilometers, or more, the additional wheel on the Stewart-Warner design would no longer register whole miles or kilometers but it would indicate that the vehicle mileage had exceeded 99,999. Thus, the Stewart- Warner design, as we understand it, would apparently comply with section 4.2.3's requirement that each odometer indicate that such mileage has been exceeded.

Finally, I would emphasize that this letter only represents the agency's opinion based on the information supplied in your letter and the model that you provided. The National Highway Traffic Safety Administration does not pass approval on any vehicle design or design for vehicle equipment prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles or items of vehicle equipment comply with all applicable safety standards and regulations and to certify its vehicles or items of vehicle equipment in accordance with that determination.

I hope that you will find this response helpful and have pot been greatly inconvenienced by our delay in sending it to you.

Sincerely,

Frank Berndt Chief Counsel

January 24, 1980

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U. S. Department of Transportation 400 - 7th Street, S. W., Room 5219 Washington, D. C. 20590

Dear Mr. Berndt:

This is to request approval of the design approach of the Stewart-Warner Corporation to comply with Section 4.2.3 of Federal Motor Vehicle Safety Standard No. 127--Speedometers and Odometers.

The design approach represents the outgrowth of a 100,000-mile odometer concept originally presented on December 12, 1979, to NHTSA personnel by representatives of Stewart-Warner. At the time of this meeting, our approach to satisfying the requirements of the standard to have odometers indicate when they have exceeded 99,999 whole miles or kilometers was to add a sixth pinion gear to the assembly. This pinion gear was to have two-thirds of its circumference coated with a fire orange fluorescent color, thereby serving as an indication to the operator that the mileage on the vehicle was in excess of 99,999 miles or kilometers. It was to be installed in such a way that an area of approximately .125 x .375 inches would be visible on the left hand side of the odometer when the vehicle would be operating between 100,000 and 299,000 miles or kilometers.

The aforementioned approach to meeting the FMVSS 127 requirements was discarded when the NHTSA personnel indicated some doubt as to whether this approach would clearly indicate to the operator when the vehicle had exceeded 99,999 miles or kilometers. After some discussion of other approaches to resolving this problem, it was agreed by all parties that the digit "1" must appear on the left hand side of the odometer if it was to clearly indicate having reached the 100,000 mile or kilometer distance.

Based on the above, the Stewart-Warner design has been changed to incorporate a seventh odometer wheel, or a sixth wheel if the odometer does not register tenths of a mile, printed with a series of number "1" on the outside periphery of the wheel. Thus, the odometer will indicate an excess of 100,000 miles or kilometers after the vehicle has traveled over 99,999 miles or kilometers.

Your prompt approval of the aforementioned design approach as a means of meeting the requirements of Section 4.2.3 of FMVSS 127 will be appreciated. A prototype mechanism equipped with a 100,000-mile odometer assembly is available for your inspection if it will assist in your review of this request.

Yours sincerely,

R. W. Strauss

RWS/jp