United States Department of TransportationInterpretation ID: aiam4788
Vice President Industry-Government Affairs Nissan Research & Development
Inc. 750 17th Street NW Suite 902 Washington
DC 20006;
"Dear Mr. Nishibori: This responds to your letter dated June 28, 199 requesting an interpretation of how the requirements of FMVSS 101, Controls and Displays, would apply to two vehicle systems Nissan is considering using. By way of background information, the National Highway Traffic Safety 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 motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter and during a discussion between Kazuo Iwasaki of your staff and Mary Versailles of my staff in our offices on July 13th. I. Car Phone Nissan is considering introducing a car phone in certain passenger cars which has five illuminated displays. The first display shows the number being dialed. The display is illuminated whether or not the phone is in use, and the number dialed continues to be displayed while the phone is in use. The second display illuminates the push buttons. The display becomes illuminated when the first button is pushed, and remains illuminated for 10 seconds. The remainder of the car phone displays are LED indicators. The first indicator (IU) is illuminated when the phone is 'in use'. The second indicator (NS) is illuminated when cellular phone service is not available. The third indicator (RM) is illuminated when outside the system's local operating area if the system is able to lock onto an available phone line. It is our understanding that there will be times when none of these three LED's will be illuminated and times when more than one of the LEDs could be illuminated (for example, both the IU and RM indicators). None of the car phone displays can be turned off while the ignition switch is in the 'ON' position. The illumination is not variable in any display. You asked whether the car phone displays are 'telltales' or other 'sources of illumination,' within the meaning of section S5.3.5, and whether the system is consistent with the requirements of FMVSS 101. Based upon our understanding of their functioning, the three LED indicators (IU, NS, and RM) would appear to be telltales. Both the IU and RM displays 'indicate the actuation of a device', while the NS display indicates 'a failure to function'. Because the displays are not listed in the standard, and because they are exempt from the requirements of section S5.3.5 because they are telltales, they are not subject to any illumination requirements. The other displays are not telltales. The functions of both the first display ('number dialed') and the second display ('push button') are not among those listed in the definition of a telltale. The 'number dialed' display provides information in much the same way as a fuel gauge. The illumination of the push buttons functions to facilitate dialing. Because these displays are not among those listed in Standard No. 101, and because they are not telltales, they are subject to the requirements of section S5.3.5. Therefore, these displays must 'have either (1) light intensity which is manually or automatically adjustable to provide at least two levels of brightness, (2) a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off.' Based upon your description, none of these requirements are currently met. II. Air-conditioning Indicator Light In certain vehicles, Nissan uses an indicator light that is illuminated only if both the air-conditioning operating switch and the ignition switch are in the 'ON' position. You indicate that you believe the indicator is a telltale, and that if it is a telltale 'it would appear to meet the requirements of section 5.3.4, since the display is bright enough to be visible in all ambient lighting conditions.' Because the indicator light indicates actuation of a device, i.e., the air conditioner, you are correct that it is a telltale. NHTSA would like to clarify that, with the exception of the requirements of section S5.3.5, FMVSS 101 regulates only controls and displays listed in the standard. Since the air-conditioning indicator light you describe is not listed in the standard, and because telltales are exempt from the requirements of section S5.3.5, there are no illumination requirements. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";