Interpretation ID: aiam3263
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 requeste 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 odomete other than a motorcycle odometer:; >>>'clearly indicate to the vehicle driver by a sixth wheel or digi 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 registe 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 milage 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 emphasis that this letter only represents the agency' 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 not bee greatly inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel