Interpretation ID: 3236o
General Manager
Austin Rover
U.S. Liaison Office
8953 N.W. 23 Street
Miami, Florida 33l72
Dear Mr. Woolner:
This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. l0l, Controls and Displays. You asked about the illumination requirements applicable to a trip computer display. According to your letter, the trip computer display is provided in addition to a fuel gauge and a speedometer/odometer. The trip computer is able, among other functions, to display supplemental information concerning fuel consumption, fuel used, average speed, trip distance and distance to arrival. As discussed below, this letter confirms your understanding that illumination is not required for the trip computer display, but, if illumination is provided, it is subject to the requirements of section S5.3.5 of the standard. This letter also addresses the illumination requirements applicable to a vehicle condition monitor.
By way of background information, the National Highway Traffic Safety Administration 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 and equipment meet applicable safety standards. The following represents our opinion based on the facts provided in your letter.
Standard No. l0l requires that vehicles with any display listed in the standard must meet specified requirements for the location, identification and illumination of such display. See section S5. Among the displays listed in Standard No. l0l are the fuel level telltale, fuel level gauge, speedometer and odometer. See section S5.l and column l of Table 2.
It is our opinion that a trip computer provided in addition to a fuel gauge and speedometer/odometer is not considered a fuel level gauge, speedometer or odometer within the meaning of Standard No. l0l. Moreover, a trip computer is not otherwise included among the displays listed in the standard. Since Standard No. l0l's illumination requirements other than those of section S5.3.5 only apply to displays listed in the standard, they are not applicable to the trip computer.
As you suggest in your letter, if illumination is provided for the trip computer display, the illumination is subject to the requirements of section S5.3.5. That section specifies requirements for any source of illumination within the passenger compartment which is forward of a transverse vertical plane 4.35 inch rearward of the manikin "H" point with the driver's seat in its rearmost driving position, which is not used for the controls and displays regulated by the standard, which is not a telltale, and which is capable of being illuminated while the vehicle is in motion.
In a telephone conversation with Edward Glancy of my staff, Mr. Marx Elliott advised that you are also interested in what illumination requirements may be applicable to a vehicle condition monitor. According to the information provided with your letter, the vehicle condition monitor indicates the following: door or trunk lid not shut, low outside air temperature, lamp failure, low washer fluid, and low engine coolant.
Each of the displays included in the vehicle condition monitor is a telltale. However, none of the telltales are among the displays listed in the standard. We note that the information provided with your letter indicates that the vehicle condition monitor illustrates, using a vehicle map, the operation of several lamps. If a lamp fails, the vehicle condition monitor causes the appropriate segment in the vehicle map to extinguish. While the headlamp high beam is among the lamps for which the vehicle condition monitor provides information, Mr. Elliott has advised us that this information is supplemental to the traditional high beam telltale provided on the instrument panel. It is our opinion, based on these facts, that such a supplemental display is not considered a high beam telltale within the meaning of Standard No. l0l.
The telltales included in the vehicle condition monitor are not subject to any illumination requirements. Since none of the telltales included on the vehicle condition monitor are listed in Standard No. l0l, they need not meet the illumination requirements specified by that standard for telltales. Moreover, as indicated by the language of section S5.3.5, quoted above, the illumination requirements of that section do not apply to telltales.
Sincerely
Erika Z. Jones Chief Counsel
/ref:101 d:ll/23/88