Interpretation ID: aiam4340
Chief Co-ordinator
Technical Administration Department
Daihatsu Motor Co.
Ltd.
1. Daihatsu- cho
Ikeda City
Osaka Prefecture
JAPAN;
Dear Mr. Tsujishita: Thank you for your letter requesting an interpretation of th requirements of three of our safety standards. This letter responds to your question concerning Standard No. 101, *Controls and Displays.* A response to your question concerning Standard 219 was sent to you earlier, and we expect to respond to your question concerning Standard No. 201 shortly.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; You asked whether Standard No. 101's illumination requirements apply t controls and displays not otherwise regulated by the standard. You quoted section S5.3.3's requirements for the light intensities of informational readout systems and asked whether those requirements apply to the following such items: digital clock using liquid crystals, radio employed digital frequency indicator using liquid crystals, and miscellaneous illuminations for conventional analog clock, cigar lighter, ashtray, and radio control switches, etc., which are lighted only when the headlights or parking light are activated.; I would like to note that Standard No. 101's requirements for ligh intensities were amended in a final rule published in the Federal Register (52 FR 3244) on February 3, 1987. An effective date of March 5, 1987, was adopted for most of the amendments. Subsequently, in response to petitions for reconsideration, NHTSA amended 49 CFR Part 571 to permit compliance with either the earlier version of the standard, reissued as Standard No. 100, or the amended standard until September 1, 1989. 52 FR 7150, March 9, 1987. I have enclosed copies of those notices for your convenience.; In answering your question, I will separately discuss the requirement for vehicles manufactured on or after September 1, 1989, and vehicles manufactured before that date.; *Vehicles manufactured on or after September 1, 1989* Vehicles manufactured on or after September 1, 1989, must meet th requirements of the current version of Standard No. 101. Secton S5.3.5 provides:; >>>S5.3.5 Any source of illuminating within the driver's forward fiel of view which is not used for the controls and displays regulated by this standard, and which is capable of being illuminated while the vehicle is in motion, must have either a variable intensity, a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or a means of being turned off. This requirements shall not apply to buses that are normally operated with the passenger compartment illuminated.<<<; As noted in your letter, the items you listed are not among th controls and displays generally regulated by Standard No. 101. However, if sources of illumination for those items are within the driver's forward field of view and are capable of being illuminated while the vehicle is in motion, they must meet the requirements of section S5.3.5.; *Vehicles manufactured before September 1, 1989* Standard No. 100, i.e. the earlier version of Standard No. 101, applie only to vehicles manufactured before September 1, 1989. The application section of Standard Nos. 100 and 101 make it clear that manufacturers have the option of meeting the requirements of either standard for any control, display or illumination until September 1, 1989. Also, the application section of Standard No. 101 provides that if no requirements are specified in Standard No. 100 for a control, display, or illumination, none need be met as a result of Standard No. 101 for motor vehicles manufactured before September 1, 1989.; Section S5.3.3 of Standard No. 100 provides: >>>Light intensities for controls, gauges, and their identificatio shall be continuously variable from: (a) A position at which either there is no light emitted or the light is barely discernible to a drive who has adapter to dark ambient roadway conditions to (b) a position provided illumination sufficient for the driver to identify the control or display readily under conditions of reduced visibility. Light intensities for informational readout systems shall have at least two values, a higher one for day, and a lower one for nighttime conditions. *The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph.* (Emphasis added.)<<<; In considering manufacturer options under Standards No. 100 and 101 for vehicles manufactured before September 1, 1989, the following points should be noted:; >>>(1) Some illumination covered by the highlighted language o Standard No. 100 are not covered by section S5.3.5 of Standard No. 101. An example is a control located in the rear seating area that is illuminated only when the headlights are activated. Since a manufacturer may meet the requirements of either Standard No. 100 or Standard 101 for any illumination and no requirement need be met for such illuminations.; (2) Some illuminations not covered by the highlighted language o Standard No. 100 are covered by section S5.3.5 of Standard No. 101. An example is a clock, located in the driver's forward field of view, which is always illuminated as a result of utilizing light emitting diodes. No requirement need be met for such illuminations (for vehicles manufactured before September 1, 1989).; (3) Some illuminations covered by the highlighted language of Standar No. 100 are also covered by section S5.3.5 of Standard No. 101. For these illuminations, the requirements of section S5.3.5 of Standard No. 101 are more flexible. While the highlighted language of Standard No. 100 provides that such illuminations must, depending on the illumination, be either continuously variable or have at lest two values, one for day and one for night, section S5.3.5 of Standard No. 101 provides three options for all such illuminations. Such illuminations must have either a variable intensity, i.e., at least two levels of intensity, as single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or a means of being turned off.<<<; Sincerely, Erika Z. Jones, Chief Counsel