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Interpretation ID: nht87-2.25

TYPE: INTERPRETATION-NHTSA

DATE: 06/29/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Hisashi Tsujishita

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department 1. Diahatsu-cho, Ikeda City Osaka Prefecture JAPAN

Dear Mr. Tsujishita:

Thank you for your letter requesting an interpretation of the 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 No. 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 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 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 to 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 t hose 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 c ontrol switches, etc., which are lighted only when the headlights or parking lights are activated.

I would like to note that Standard No. 101's requirements for light 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. S ubsequently, in response to petitions for reconsideration, NHTSA amended 49 CFR Part 511 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, Marc h 9, 1987. I have enclosed copies of those notices for your convenience.

In answering your question, I will separately discuss the requirements 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 the requirements of the current version of Standard No. 101. Section S5.3.5 provides:

S5.3.5 Any source of illumination within the driver's forward field 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 requirement shall not apply to buses that are normally operated with the passenger compartment i lluminated.

As noted in your letter, the items you listed are not among the 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 illu minated 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, applies only to vehicles manufactured before September 1, 1989. The application sections of Standards Nos. 100 and 101 make it clear that manufacturers have the option of meeting the requir ements 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 identification shall be continuously variable from: (a) A position at which either there is no light emitted or the light is barely discernible to a driver who has adapted to dark ambient roadway conditio ns to (b) a position providing 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 illuminations covered by the highlighted language of 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. Sin ce a manufacturer may meet the requirements of either Standard No. 100 or Standard No. 101 for any illumination and no requirement is specified for such illuminations in Standard No. 101, no requirement need be met for such illuminations.

(2) Some illuminations not covered by the highlighted language of 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 utilizi ng 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 Standard 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 highlighte d language of Standard No. 100 provides that such illuminations must, depending on the illumination, be either continuously variable or have at least 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; a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions; or a means of being t urned off.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

Dec. 24 , 1986

Ms. Erika Z. Jones Chief Counsel Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones:

The purpose of this letter is to respectfully inquire NHTSA's interpretations with regard to the Federal Motor Vehicle Safety Standards (FMVSS) Nos. 101, 201, and 219.

We wish we could have your early and kind response to the questions on the following pages.

We thank you in advance for your kind attention to this matter.

Sincerely yours,

H.Tsujishita Chief Co-ordinator of Technical Administration Dept. Head Office

Enclosure : QUESTIONNAIRE (1),(2),(3) cc: Mr. R. Busick, Olson Engineering Inc.

QUESTIONNAIRE (1)

FMVSS No. 101 ; Controls and Displays

Paragraph S5.3.3 of FMVSS No. 101 provides that;

"Light intensities for informational readout systems shall have at least two values, a higher one for day, and a lower one for night time conditions. The intensity of any illumination that is provided in the passenger compartment when and only when the h eadlights are activated shall also be variable in a manner that complies with this paragraph."

However the applicable items(illuminations) of the above provision are not necessarily definitely for us.

We believe that these provisions are applied only to the illuminations for the controls or gauges which are somehow regulated otherwise in FMVSS No. 101, and are not applied to the illuminations which are optionally equipped and are not otherwise mention ed in the standard, such as following illuminations in concrete;

(1) Digital clock using liquid crystals (2) Radio employed digital frequency indicator using liquid crystals

(3) Miscellaneous illuminations for conventional analog clock, cigar lighter, ashtray, and radio control switches, etc. which are lightened only when the headlights (parking lights) are activated.

We would like to confirm that the above items are not applied the variable illumination requirements. Please advise us in detail in this matter.

QUESTIONNAIRE (2)

FMVSS Ho. 201 ; Occupant Protection in Interior Impact

Paragraph S3.5.1(c) of FMVSS No. 201 provides the dimensional requirements for armrests as follows;

"Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically inside elevation, provide at least 2 inches of coverage with the pelvic impact area."

Our concern, however, centers on how to measure the armrest vertically in side elevation.

We believe that this provision does not necessarily require completely plain area of 2 in. x 2 in. on the armrests such as Ill.1 below, and that the armrests which have, to some extent, rounded inside surface, such as Ill.2, shall be deemed in compliance with this provision.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

And we also believe that no matter how the armrests have more than 2 in. side elevation considerably sharply projected armrests such as Ill.3 shall be deemed in noncompliance with the provision.

However, we can not be sure the criteria for distinguish Ill.2 from Ill.3. Though we think the most important point to be concerned is its contactability by the occupant , we can not necessary surely know the procedures to prove the contactability.

Therefore we would like to ask your kind favor of showing us ' the guideline to how to measure armrests to decide the compliancy to S3.5.1(c).

And further, as we are designing a little more complicated shape such as shown on the next page, we wish you would advise us about the compliancy of the armrest.

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FMVSS No. 219 ; Windshield Zone Intrusion

Paragraph S5 of FMVSS No. 219 provides:

"When the vehicle ......, no part of the vehicle outside the occupant compartment, except windshield molding and other components designed to be normally in contact with the windshield, shall penetrate the protected zone template, ...."

In the case that the windshield wiper penetrate the protected zone template ( by some reason such as pushed by the deformed cowl , or accidentally turned-on of wiper switch as a result of contact with test dummy), we would like to confirm whether the veh icle is deemed in compliance or not. (Refer to the illustration below)

We believe the penetration of wiper blades shall be deemed in compliance because the wiper blades are designed to be normally contact with the windshield. The wiper arms, however, only contact with the windshield though the wiper blade. Please advise us about the exemption of wiper arms from this intrusion provision.

SEE HARD COPY FOR GRAPHIC ILLUSTRATION