Mr. Orlando Ferreira
Orion Bus Industries Ltd.
5395 Maingate Drive
Mississauga, Ontario L4W 1G6
Canada

Dear Mr. Ferreira:

This responds to your FAX message to Mr. Jere Medlin of this agency, asking whether your "master switch" on a transit bus must be illuminated pursuant to Standard No. 101, Controls and displays. Your master switch has four controls, "engine stop," "run," "lights," and "park." In a telephone conversation with Mr. Medlin, you explained that your "run" control functions as an "engine start" control, and your "park" control functions as a "clearance lamps systems" control.

As explained below, Standard No. 101 specifies illumination for the "engine stop" and "park" controls, but not for the "run" and "light" controls. In addition, there are identification requirements for those controls.

Your drawing of the master switch shows that the switch resembles a tuning knob on a radio. Like a knob, the switch can be turned to each of the above four positions, one position at a time. Because turning the master switch knob to each position activates the described function, we would consider each position to be a separate control.

You write that the master switch will be placed on a "driver's side control panel," a location that subjects controls to Standard No. 101's illumination requirements. S5.3.1 of Standard No. 101 (referencing Tables 1 and 1(a) Identification and Illumination of Controls), specifies that if:

C a control is provided, C is listed in column 1 of either Table 1 or 1(a), C and is accompanied by the word "yes" in the corresponding space in column 4, Illumination, of the table,

the "identification ... of any control" shall be capable of being illuminated whenever the headlights are activated.

"Engine stop" control The identification of the "engine stop" control must be capable of being illuminated whenever the headlights are activated. This is because in Tables 1 and 1(a), the "engine stop" control is specified in column 1, and accompanied by "yes" in the corresponding space in column 4 of each table.

"Park" control Two issues are raised by your "park" control. The first relates to Standard No. 101's requirements for identifying controls. Under the standard, the control that regulates the parking lights is the "clearance lamps system" control, rather than the "park" control. Since your control regulates the parking lights, it must be identified as "Marker Lamps", "MK Lps" or (as you propose) with the symbol specified in column 3 of Table 1. Labeling the control as "park" could confuse some persons into thinking "park" is a transmission park position.

The second issue is the illumination requirement. The identification of the control must be capable of being illuminated whenever the headlights are activated. As noted above, your park control has to be identified as "Marker Lamps" or "MK Lps". In Table 1, the control is specified in column 1, and accompanied by "yes" in the corresponding space in column 4. Thus, the control must be illuminated.

"Run" control The same two issues discussed in our answer directly above, pertain to this control. First is Standard No. 101's requirements for identifying controls. Under the standard the control that will start the engine must be identified as "engine start" (rather than "run") as described in both Tables 1 and 1(a), when it is separate from the key locking system (as is yours).

The control need not be illuminated. In both Tables 1 and 1(a), the "engine start" control (which is the correct identification of the control) is specified in column 1, without a corresponding "yes" for illumination in column 4 of either table.

"Lights" control The same two issues discussed above are relevant here. The illustration you enclosed with your letter shows that you use both the word "Lights" and an identifying symbol to identify your Lights control. We are not sure that you are correctly using the symbol. The symbol you use is listed in Table 1 of Standard No. 101 as that for the master lighting switch. A master lighting switch regulates all exterior vehicle lights. If your "lights" control only regulates headlamps and taillamps, and not all exterior vehicle lights, please designate the headlamps and taillamps as specified in column 3 of Table 1.

The "lights" control need not be illuminated. In both Tables 1 and 1(a), the "lights" control is specified in column 2, without a corresponding "yes" for illumination in column 4 of either table.

I hope this information is helpful. If you need any further information, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992. Our FAX number is (202) 366-3820.

Sincerely,

John Womack Acting Chief Counsel

ref:101 d:10/25/96