Mr. Michael X. Cammisa
1050 K St., N.W., Suite 650
Washington, D.C. 20001
Dear Mr. Cammisa:
This responds to your predecessor organizations (Association of International Automobile Manufacturers, Inc.) request for an interpretation of horn control identification requirements specified in Federal Motor Vehicle Safety Standard (FMVSS) No. 101, Controls and Displays.
As you are aware, in a final rule of August 13, 2009 (74 FR 40760), we amended S5.2.1 of FMVSS No. 101 to read as follows:
S5.2.1 * * * No identification is required for any horn (i.e., audible warning signal) that is activated by a lanyard or by the driver pressing on the center of the face plane of the steering wheel hub; or for a turn signal control that is operated in a plane essentially parallel to the face plane of the steering wheel in its normal driving position and which is located on the left side of the steering column so that it is the control on that side of the column nearest to the steering wheel face plane. However, if identification is provided for a horn control in the center of the face plane of the steering wheel hub, the identifier must meet Table 2 requirements for the horn.
In the preamble to this final rule, NHTSA summarized a question raised by your organization in a comment as follows:
if a manufacturer provides a horn control activated by pressing on the center of the steering wheel and provides a second horn control off center, near the edge of the hub, to identify the supplemental horn control that operates by tilting the plane of the hub whether the second control must met the S5.4.3 requirement for color contrast. (See 74 FR at 40762)
NHTSA understood the AIAM comment as indicating that there would be two separate horn controls on the steering wheel and provided an answer based on that understanding. Subsequently, at a meeting with NHTSA staff, it became apparent that your organization was referring to one horn control on the steering wheel, which could be actuated by pressing anywhere on the steering wheel hub. In your follow-up letter to us of January 29, 2011, you state: In fact, the common designs provide a single control for activation, and that single control allows the horn to be activated by pressing anywhere on the steering wheel hub. The clarification that the horn is actuated by pressing anywhere on the steering wheel hub, including the center of the face plane of the steering wheel hub led you to ask the following questions:
1) Do the horn controls commonly in use today, which activate the horn when any portion of the steering wheel hub is pushed (including the center of the hub), require identification?
In response to your question, I will assume that the steering wheel hub has only one horn control, and the horn controls location includes the center of the face plane of the steering wheel hub. Assuming this is the case, as long as the horn is actuated when the center of the face plane of the steering wheel hub is pressed, the horn control need not be identified.
However, if the steering wheel hub has more than one horn control, our answer in the preamble to the final rule of August 13, 2009, at 74 FR 40762 would apply:
As a result of todays final rule, identification is not required for those horn controls that are placed in the center of the face plane of the steering wheel hub. All other horn controls must meet all FMVSS No. 101 requirements that apply to horns.
2) May manufacturers voluntarily affix a horn symbol that is embossed, but not color contrasting, to the hubs center or toward the edge of the hub, for horns that are activated by pressing the center of the steering wheel hub?
In the final rule of August 13, 2009, we amended S5.4.3 to read as follows:
S5.4.3 Each identifier used for the identification of a telltale, control or indicator must be in a color that stands out clearly against the background. However, this requirement does not apply to an identifier for a horn control in the center of the face plane of the steering wheel hub.
Thus, the color contrast requirement does not apply to an identifier for a horn control in the center of the face plane of the steering wheel hub. This would be true whether the identifier was placed in the hubs center or toward the edge of the hub.
I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at (202) 366-2992.
O. Kevin Vincent
ref: Std. No. 101