Interpretation ID: 1984-1.30

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/84

FROM: AUTHOR UNAVAILABLE; NONE; NHTSA

TO: Jaguar Cars Inc. -- C. Diane Black, Legislation and Compliance

TITLE: NHTSA RESPONSE TO PETITION

TEXT:

February 9, 1984

RE: FMVSS 101 Docket 1-18, Notice 23 7-27 Notice 24

Dear Ms. Steed:

On December 22, 1982, BL Technology Limited submitted a petition to your predecessor regarding a Notice of Proposed Rulemaking on Controls and Displays.

We are nearing the point of no return with a new model where "substantially resemble" and ISO parking brake symbol become extremely important.

I have attached one copy of our 1982 request and need to know if you and your staff require any other information from us to allow a decision on this request.

Sincerely,

C. Dianne Black Manager-Engineering Legislation & Compliance

CDB:as Attach.

22nd December 1982 Mr. R. Peck, Administrator, National Highway Traffic Safety Administration, 400 7th Street SW, WASHINGTON DC 20490, U.S.A.

Dear Mr. Peck

FMVSS 101 Controls & Displays Notice of Proposed Rule Making (Dockets 1-18, Notice 23 70-27; Notice 24)

The following petition is submitted on behalf of BL PLC (Cars Group) manufacturers of Austin, MG, Jaguar, Rover and Triumph cars.

We refer to the NHTSA proposal to update FMVSS 101, Controls and Displays, by adding or modifying several symbols to bring the standard into harmony with the latest documents promulgated by the International Standards Organization.

As manufacturers of automobiles for markets throughout the world, we strongly support proposals that lead to the harmonization of vehicle standards. Notwithstanding this principle, we also feel that vehicle standards should not impede the introduction of new technology into the automobile.

The size and shape of symbols for controls, indicators and telltales is constrained by the ISO grid pattern, and in general, the shape of symbols is defined by a template in the display, the shape and continuity of which can be readily controlled. However, with the introduction of Informational Readout Displays and their associated 'dot matrix' character generation system, exact reproduction of smooth continuous curved shapes or lines may not be possible. The drivers recognition of such displays is not adversely affected and the ability to present additional information selectively, whilst not saturating the driver with an array of individual displays, has distinct economic advantages.

In Docket 1/18 Notice 13 the Administration recognized that minor deviations such as we have described should be permitted, provided the symbols so produced substantially resemble those in Table 2. To give effect to the Administration's position we therefore petition that S.5.2.3 be amended by the addition of a final sentence:-

'The provisions of this Section shall be considered to have been met if the symbols displayed substantially resemble those designated in Column 4 of Table 2.'

With regard to the specific NHTSA request for comments on the use of a parking brake symbol, we request that the ISO symbol should be permitted as an alternative to words when a separate parking brake indicator lamp is provided.

Yours sincerely,

M. W. Lewis, Chief Engineer, Admin. & External Affairs

MWL/KD/VLS/A70/2e

C. Dianne Black Manager-Engineering Legislation and Compliance Jaguar Cars, Inc. 600 Willow Tree Road Leonia, NJ 07605

Dear Ms. Black:

This is in response to your letter in which you request information on the status of your Petition for Rulemaking on Controls and Displays submitted December 22, 1982, and granted on December 12, 1983.

Your petition along with several others is being reviewed by a Task Force set up by the Administrator. Its purpose is to rewrite FMVSS No. 101 to reflect changes in technology which impact the control and display systems planned for future production.

A number of the petitioners have requested modifications to permit various Informational Readout Displays or combinations of telltales and displays which are currently not permitted by one or more sections of the standard. Your petition asks for inclusion in the standard of this statement. "The provision of this section shall be considered to have been met if the symbols displayed substantially resemble those designated in Column 4 of Table 2." While providing manufacturers great latitude for interpretation, this addition would make the standard unenforceable without some design or performance boundaries on the words "substantially resemble."

We do not know how to set these performance limits and thus are retaining the policy established in the preamble to Notice 13 which asked manufacturers to produce symbols which substantially resemble those in the Tables. This approach allows thc agency to treat each symbol noncompliance on a case by case basis by weighing the impact on safety produced by the noncompliance.

To date all symbols have complied with the standard regardless of the technology used to make them visible to the driver. We note that you have not described the limitations of your dot matrix display in quantifiable terms and suspect that, like us, you have not found an easy way to define the relationship between density, color, distance from the driver, etc, vis a vis the perceived shape by the driver.

We have decided to terminate rulemaking on this subject at this time and, thus, will not be placing the words you recommended in the text of the standard. However, although the specific words are not included in the standard, the agency's intent should be clear from Notice 13 and this letter.