United States Department of TransportationInterpretation ID: aiam3651
Manager
Compliance and Recall
Volvo White Truck Corporation
P.O. Box D-1
Greensboro
NC 27402-1200;
Dear Mr. Lawrence: This responds to your letter concerning Safety Standard No. 101 *Controls and Displays*. You asked whether the standard's identification and illumination requirements are applicable to an optional windshield wiper control you are planning to make available on some heavy duty trucks.; By way of background information, the agency does not provide approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is up to the manufacturer to assure that its vehicles and equipment comply with applicable Federal motor vehicle safety standards. The following interpretation represents our opinion based on the facts provided in your letter. It also takes into account information provided in a follow-up telephone conversation with Edward Glancy of this office.; The standard wiper controls for the vehicles in question consist of tw knobs which independently control the left and right wipers. These controls provide both the on-off function and variable speed. According to your letter, these controls are identified and illuminated as required by the standard.; The proposed optional control, the specific subject of your letter would provide a time delay for windshield wiper operation during light mist conditions. The control would be a knob which, if turned to the left, would provide no pause, and if turned toward the right, would offer a variable time delay.; We are unable to agree with your suggestion that the control is no covered by Standard No. 101. As discussed below, Standard No. 101 requires that this control, like the standard controls, be identified and illuminated in accordance with the standard's requirements. Additional words or symbols may be provided for the purpose of clarity.; Section S5 of Standard No. 101 requires, among other things, that eac truck manufactured with any control listed in S5.1 or in column 1 of Table 1 meet the requirements of the standard for the location, identification, and illumination of such control. One of the controls listed by S5.1 is 'windshield wiper.' Also, 'windshield wiping system' is among the controls listed in column 1 of Table 1. The issue raised by your letter is therefore whether an optional control for intermittent wiper operation is within the meaning of 'windshield wiper' control and/or 'windshield wiping system' control. It is our interpretation that such a control is within the meaning of both terms.; Neither the term 'windshield wiper' control nor 'windshield wipin system' control is limited to specific wiper functions, such as on-off, variable speed, etc. Since a control for intermittent wiper operation controls one function of windshield wipers, it is a 'windshield wiper' control or 'windshield wiping system' control. Such a control is therefore subject to the standard's requirements for location, identification and illumination.; We would note that while section S5.2.1 and Table 1 require such control to be identified by the symbol specified for windshield wiping system controls, additional words or symbols may be used at the manufacturer's discretion for purposes of clarity. Since your vehicles would have three windshield wiper controls, you may wish to provide such additional words or symbols to explain the function of each.; Sincerely, Frank Berndt, Chief Counsel