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Interpretation ID: nht80-3.10

DATE: 06/25/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of April 22, 1980, asking two questions about Standard No. 101-80, Controls and Displays.

your first question concerns whether a display incorporated in the tachometer instrument face that shows which gear position has been selected by the automatic transmission control lever is an "informational readout display." You explained that the display "consists of 5 stacked transparent screens on which are printed 'D', '2', 'N', 'P', 'R' to identify the transmission control lever positions. Each screen is illuminated by an incandescent bulb which is energized selectively through contacts at the control lever."

The display which you have described is not an informational readout display. Section 4 of the standard defines "informational readout display" as "a display using light-emitting diodes, liquid crystals or other electro illuminating devices where one or more than one type of information or message may be displayed." As explained in the June 26, 1978, preamble to the final rule establishing Standard No. 101-80, the agency did not want to inhibit the development of electronic "readout" panels which present the driver with specific information concerning vehicle and environmental conditions affecting safety. The preamble further described these devices as displays "capable of exhibiting information and warning with word messages and not with symbols." The device you have described uses symbols instead of words and conventional incandescent bulb technology instead of electronic technology and thus is not an informational readout display.

The display you have described is a guage. Section 4 of the standard defines "guage" as "a display that is listed in S5.1 or in Table 2 and is not a telltale." Section 5.1 and Table 2 do not identify the automatic gear position as a telltale. Likewise, an automatic gear position display does not meet the definition of "telltale." Section 4 of the standard defines "telltale" as "a display that indicates, by means of a light-emitting signal, the actuation of a device, a correct or defective functioning or condition, or failure to function." In this case, the display does not indicate the activation of a device since a transmission is always activated. Likewise, the display does not indicate that the transmission is functioning correctly or improperly or has failed to function, Section 5.3.3 provides that the light intensity of each gauge shall be continuously variable. The display you have described does not comply with section 5.3.3, since it only has two light intensities.

Your second question concerns "a display adjacent to the shift control lever which shows the transmission shift level sequence. The identifying characters 'P', 'R', 'N', '2', 'D', are shown on a transparent screen, the position selected is indicated by a colored panel which moves with the shift control level." You explained that the "colored panel only is illuminated when the headlights are switched on showing which position is selected, the other positions on the display are not illuminated." [Emphasis in the original] You asked whether the display is exempt from the illumination requirements of the standard because it is "a hand-operated control mounted upon a . . . floor console" or because it is a "telltale." Section 5.1 and Table 2 of the standard classify an automatic gear position indicator as a display. Thus, an automatic gear position indicator cannot be a "hand-operated vehicle control."

Further, the display that you have described is not a "telltale." As explained above, an automatic gear position display is a gauge. According to your description, the display "Only is illuminated when the headlights are switched on." Section 5.3.3 of the standard requires the light intensity for gauges to be continuously variable. Since the illumination for the display you have described apparently is not variable, it would not comply with the standard.

If you have any further questions, please let me know.

SINCERELY,

AMERICAN HONDA MOTOR CO., INC.

April 22, 1980

Chief Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Sir:

This is to request your official interpretation regarding the applicability of certain provisions of FMVSS 101-80 to items of equipment which are intended to be used in 1981 model year Honda automobiles equipped with automatic transmission.

1. Incorporated in the tachometer instrument face is a display to show which gear position has been selected by the automatic transmission control lever. This display consists of 5 stacked transparent screens on which are printed 'D' '2', 'N', 'P', 'R' to identify the transmission control lever positions. Each screen is illuminated by an incandescent bulb which is energized selectively through contacts at the control lever. There are two light intensities for these bulbs; high enough for daylight visibility and reduced when the headlights are switched on. The display is activated whenever the ignition switch is in the "on" position. The display is identified only in the owners manual, not adjacent to the display.

We classify this as an "informational readout display" using an" "other electro illuminating device" and, as such, complying with the requirements of FMVSS 101-80.

2. There is a display adjacent to the shift control lever which shows the transmission shift lever sequence. The identifying characters 'P', 'R', 'N', '2', 'D' are shown on a transparent screen, the position selected is indicated by a colored panel which moves with the shift control lever. The colored panel only is illuminated when the headlights are switched on showing which position is selected, the other positions on the display are not illuminated.

We believe that, either this display is exempted from the requirements of FMVSS 101-80 under section S5.3.1 as a "hand-operated control mounted upon a . . . . floor console", or that the display and colored panel constitute a "telltale". As such, they comply with the requirement of S5.3.3 in that the light intensity of the telltale is not variable and the telltale and display are visible to the driver under all daytime and nighttime conditions.

We would appreciate your earliest attention and response in this matter. Please call me at (213) 327-8280 if you have any questions.

Brian Gill Manager Certification Department