Interpretation ID: aiam3907
Manager
Truck Engineering
MMC Services Inc.
3000 Town Center
Suite 501
Southfield
MI 48075;
Dear Mr. Ogura: This responds to your letter concerning Federal Motor Vehicle Safet Standard No. 101, *Controls and Displays.* According to your letter, your trucks, which have a GVWR of more than 10,000 pounds, have a coolant temperature sensor for overheat warning and also a coolant level sensor for lack of engine coolant to prevent engine overheating. Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale. Your letter noted that Standard No. 101 specifies an identifying symbol for coolant temperatures but not a symbol for coolant level. You asked whether a system displaying the symbol specified by Standard No. 101 for coolant temperature meets the requirements of the standard. As discussed below, while some of the Standard No. 101's requirements are applicable to your trucks, the standard's telltale requirements do not apply to truck with a GVWR of 10,000 pounds or more.; Section 5, *Requirements,* states: >>>Each passenger car, multipurpose passenger vehicle, truck and bu manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car, multipurpose passenger vehicles and truck or bus *less than 10,000 pounds GVWR* with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display. (Emphasis added.)<<<; Thus, Standard No. 101's requirements for identification of control are applicable to trucks with a GVWR of 10,000 pounds or more, but the standard's requirements for identification of internal displays are not applicable to such vehicles. Since telltales for coolant temperature are a type of internal display, that requirement of Standard No. 101 is not applicable to the vehicles (more than 10,000 pounds) described by your letter.; Sincerely, Jeffrey R. Miller, Chief Counsel