Interpretation ID: 1984-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 07/05/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Grumman Olson

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis, Michigan 49091

Dear Mr. White:

This responds to our letter of May 3, 1984, asking about Standard No. 101, Controls and Displays. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listed in that table. You asked whether the symbols are required to be illuminated or whether it is permissible instead to illuminate the identifying words without illuminating the symbols. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.

By way of background information, I would note that the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.

Section S5.2.1 of Standard No. 101 generally requires that "any hand-operated control listed in column 1 of Table 1 that has a symbol designated n column 3 shall be identified by that symbol." The section states further that "(s)uch a control may, in addition, be identified by the word or abbreviation shown in column 2." The three controls noted above, heating fan, windshield wiper and washer, and defroster system, are all listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.

Section S5.3.1 of Standard No. 101 states:

Except for foot-operated controls or hand-operated controls mounted upon the floor, floor console, or steering column, or in the windshield header area, the identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompained by the word "yes" in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield.... Emphasis added.

As discussed above, the identification required by section S5.2.1 for the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word "yes" in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated. It is thus not permissible to illuminate the identifying words without also illuminating the symbols.

I would note that your letter does not provide sufficient information to determine whether the controls in your proposed design could come within any of Standard No. 101's exceptions to the illumination requirements.

Sincerely,

Frank Berndt Chief Counsel

May 3, 1984

National Highway Traffic Safety Administration Office of the Chief Counsel 400 Seventh Street S/W Washington, D. C. 20590

ATTN: Frank Berndt

Dear Sir;

Grumman Olson is a manufacturer of walk-in delivery vans. We have a customer who is asking us to use a special instrument panel that I question conforms to F.M.V.S.S. 101. The reason I question the conformity is that S5.2 of F.M.V.S.S. 101 requires that controls listed in column 1 of table 1 that have symbols designated in column 3 shall be identified by those symbols. Optionally the control may, in addition to the symbol, be identified by the word listed in column 2 of table 1.

S5.3 of F.M.V.S.S. 101 states that the identification required in S5.2 shall be illuminated if column 4 of table 1 requires it.

The controls on the instrument panel in question are identified both by the required symbol and the optional word. The symbol, however, is on the control and the word is on the panel itself. Provisions are made to illuminate the word and not the appropriate symbol. I am speaking here of the heating fan, windshield wiper and washer and the defroster system.

I have stated to our customer that the identification that is required is the symbol and it must be illuminated, not the word. I have not been able to convince them of this, so I seek an interpretation from you concerning this matter. The question I ask is, does the symbol have to be illuminated or may the identifying word be illuminated when it is provided with no illumination on the symbol?

I spoke with Ed Glancy of your office concerning this matter and he advised me that N.H.T.S.A. does not give out rulings verbally. He advised me to write this letter requesting an interpretation.

If there are any questions, please call me at your convenience.

David A. White Senior Safety Engineer

DAW/smf