Interpretation ID: nht90-1.59

TYPE: Interpretation-NHTSA

DATE: February 27, 1990

FROM: Don James -- Contracts, Stone Bennett Corporation

TO: Docket Section -- NHTSA

TITLE: Re Docket No. 88-16; Notice 3

ATTACHMT: Attached to diagram of the toggle installation & envelope (graphics omitted); Also attached to diagram of control panel with auto-neutral (graphics omitted); Also attached to diagram of control panels (text and graphics omitted); Also attached to letter dated 10-12-90 from P.J. Rice (Signature by K.W. Weinstein) to D. James (A36; Std. 102); Also attached to copy of 54 FR 29042, 7-11-89 and 55 FR 1226, 1-12-90, regarding 49 CFR Part 571 and FMVSS 201 (text omitted)

TEXT:

The above referenced Docket concerns the FMVSS Standard No. 102 and the proposed changes as they relate to Automatic Transmissions without a Park Position.

Stone Bennett Corporation has been manufacturing transmission shifting mechanisms since 1973. These mechanisms utilize pneumatics, hydraulics, or, electromotive force or any combination of the three to shift the transmission on the demand of the operato r. In all cases the transmission ranges are indicated by a series of light indicators or a sunshine readable digital display that indicates only the range selected. The method of selecting ranges is not the classic floor mounted or column mounted shift levers. Stone Bennett Corporation uses a toggle mechanism or two pushbutton switches to effect the range to range shift operation. That is, to execute a shift to an adjacent range when in the Neutral position, it will be necessary to depress a shift bu tton (push the toggle lever) to move from neutral to reverse or from neutral to drive. It is necessary to depress the pushbutton or push the toggle lever and release to allow movement through the range sequence. An example is to shift three range posit ions from drive to second in a sequence of RND321. The operator must press/release to shift to 3rd and press/release to shift from 3rd to 2nd and simarily to shift the opposite direction.

The overriding purpose of this letter is to ask for a ruling on the acceptability of providing a label indicating the range sequence on the body of the shift control console. Please see the attached documents for a visual understanding of the request.

Your immediate attention to this matter will be greatly appreciated.