Interpretation ID: nht79-4.48

DATE: 07/20/79

FROM: FRANK BERNDT -- NHTSA, DOT CHIEF COUNSEL

TO: J. C. ECKHOLD -- FORD MOTOR COMPANY

TITLE: NONE

ATTACHMT: LETTER DATED 5/23/79 FROM J. C. ECKHOLD OF FORD MOTOR COMPANY TO JOAN B. CLAYBROOK OF NHTSA

TEXT: Dear Mr. Eckhold:

This is in response to your letter of May 23, 1979, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. Specifically, you requested a clarification of Section 5.3.3 which states that each tell-tale and its identification must be "visible to the driver under all daytime and nighttime conditions." You indicated that under certain conditions the intensity and color characteristics of sun lighting could cause transitory reflections that obscure either the intensity or color, or both, of the tell-tale.

It is the interpretation of the National Highway Traffic Safety Administration that the manufacturer must manufacture a tell-tale with a light intensity that ensures visibility under the most adverse general lighting conditions. This means that the tell-tales and their identification need not be visible to the driver when the tell-tales are struck by direct sunlight. Since conditions such as these are typically short-lived, the NHTSA does not believe that the length of time the driver may be unable to view the tell-tales is significant enough to warrant requiring the manufacturer to prevent their occurrence.

Sincerely,