Interpretation ID: nht80-2.19

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: White Motor Corp

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Mr J. W. Lawrence Manager, Reliability & Government Standards White Motor Corporation 35129 Curtis Boulevard Eastlake, Ohio 44094

Dear Mr. Lawrence:

This responds to your letter of January 15, 1980, which requested an interpretation of Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You described a control to be included in heavy duty truck tractors which would operate the cab marker lights and some of the trailer lamps and asked whether Safety Standard 101 would permit labeling of the control with the words "marker lamps."

We have concluded, for the reasons stated below, that Safety Standard 101 would not permit the control to be labeled in the fashion you suggest. However, it would permit labeling of the control with the symbol for clearance lamps designated therein accompanied by the words "Clearance Lamps" or the abbreviation "C1 Lps" and by the words "marker lamps."

With respect to vehicles including trucks with gross vehicle weight ratings exceeding 10,000 pounds manufactured before September 1, 1980, S4 of Safety Standard 101 permits manufacturers to comply with its requirements or with those of Safety Standard 101-80. S4.2.1 of Safety Standard 101 requires that a control which operates clearance lamps, identification lamps and/or side marker lamps be identified with the words "Clearance Lamps" or the abbreviations "C1 Lps" as shown in Table I Column 2 of the standard. In addition, S4.2.1 provides that such a control may also be identified by one of the symbols for clearance lamps shown in Columns 3 and 4 of Table I. (See Table I, Footnote 3. S5.2.1 of Safety Standard 101-80 requires that such a control be labeled with the symbol for clearance lamps shown in Column 3 of Table I of the standard. However, this symbol may be accompanied by the word or abbreviation shown in Column 2 (i.e., Clearance Lamps or C1 Lps) and additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. (See Table I, Footnote 3.) The requirements of Safety Standard No. 101-80 will become mandatory and will supercede those of Safety Standard 101 for all vehicles to which it applies which are manufactured on or after September 1, 1980.

According to your product description, the control which you propose to label with the words "marker lamps" would operate some of the trailer lamps and the cab marker lamps which also serve as clearance lamps. Thus, the control would be considered to operate clearance lamps and marker lamps and would be subject to the provisions of Safety Standard 101, Table I, Footnote 3. Accordingly, on vehicles manufactured before to September 1, 1980, the control you propose either must be identified in one of the following methods:

1. with the words "CLEARANCE LAMPS" or the abbreviations "CL LPS", or

2. with the words or abbreviations shown in method number 1 above accompanied by the symbol shown in Column 3 of Table I or by the symbol shown in Column 4, Table I, of Safety Standard No. 101, or

3. with the symbol for clearance lamps shown in Column 3, Table I, of Safety Standard 101-80, or

4. with the symbol noted in method number 3 above accompanied by the words "clearance lamps" or the abbreviations "Cl Lps" as shown in Column 2 of Table I of Safety Standard 101-80, or

5. with the symbol and the words or abbreviations noted in method number 4 above accompanied by any additional clarifying words or symbols the manufacturer may choose.

If the control you have proposed is included in vehicles manufactured on or after September 1, 1980, it must be identified as indicated in method number 3 above and may be identified as indicated in method number 4 or 5 above. Use of method number 5 above would permit use of the words "marker lamps" in addition to the required symbol and the words "Clearance Lamps" or the abbreviation "C1 Lps."

I hope that you will find this response helpful and have not been inconvenienced by our delay in sending it to you.

Sincerely,

Frank Berndt Chief Counsel

January 15, 1980

Ms. Joan Claybrook, Administrator National Highway Traffic Safety Adm. 400 Seventh Street S. W.

Washington, D. C. 20590

Re: Request for Interpretation FMVSS-101 Control Location Identifcation and Illumination

Dear Ms. Claybrook:

White Motor Corporation requests an interpretation of FMVSS 101 Table I relative to the identification of the controls for clearance lamps, marker lamps, identification lamps and combinations thereof. This request is limited to the application of these controls to heavy duty truck tractors such as those manufactured by White.

Product Description

"Cab Over Engine" (COE) vehicles have five lamps spaced across the top of the cab. The outboard lamps are the clearance lamps when viewed from the front of the vehicle and the side marker lamps when viewed from the side of the vehicle.

"Cab Behind Engine" (CBE) vehicles have five lamps spaced across the top of the cab. The outboard lamps usually are the clearance lamps when viewed from the front of the vehicle and may be considered intermediate side marker lamps (optional, not required by MVSS-108) when viewed from the side of the vehicle. There are also side marker lamps installed near the front of the hood or fenders.

Background

Tractor manufacturers, in addition to providing the required lights on the power units, also provide the circuitry for the trailer lights. Many operators use additional trailer lamps for conspicuity and in recent years double bulb lamps for reliability have become popular. Also, many operators use an interrupter switch allowing the driver to flash some of the trailer lights for signaling purposes. These switches are not covered by FMVSS-101 and are often labeled "trailer lights" or "trailer marker lights", the latter being the more popular nomenclature. In order to increase the reliability of the lighting switches and provide for interchangability between trailers owned by various companies some tractors are being manufactured with split lighting circuits and separate switches which are identified and illuminated as required by FMVSS-101. One switch operates the tractor head lamps and tail lamps as well as the trailer taillamps. This switch may also be wired to some of the trailer clearance, identification and marker lamps. Second and third switches may activate combinations of tractor/trailer clearance, identification or marker lamps.

Interpretation Request

MVSS-101 provides labeling nomenclature for "Clearance lamps" and "Identification lamps" but none for marker lamps. It also mentions that clearance lamps combined with identification and/or marker lamps should use the labeling nomenclature clearance lamps. Relative to the five cab mounted lights (see "Product Description" section above) White considers the term "marker lamps" appropriate for a control operating the cab marker lamps and some of the trailer lamps on the basis that it is consistant with the identification of the nonregulated interrupter control (see Background section) and readily recognizable and decipherable by the average truck driver. White requests an interpretation that such a control and labeling does fall within the ambit of FMVSS-101 and is in conformance.

Sincerely,

J. W. Lawrence Manager, Reliability & Government Standards

JWL/ek