Interpretation ID: nht89-3.1

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 21, 1989

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: JIM BOWEN -- VICE PRESIDENT OF QUALITY, SERVICE AND PARTS, GULF STREAM COACH, INC.

TITLE: N

ATTACHMT: LETTER DATED APRIL 20, 1989 TO OFFICE OF CHIEF COUNSEL FROM JIM BOWEN, GULF STREAM COACH, INC. ATTACHED.

TEXT: This responds to your letter concerning the installation of a television receiver in view of the driver of a vehicle. You asked whether the television is required to be off, when the ignition switch is turned on. I regret the delay in responding. Your question is responded to below.

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 th e manufacturer to ensure that its vehicles and equipment meet applicable standards. The following represents our opinion based on the facts provided in your letter.

I have enclosed a copy of a June 4, 1987 letter, addressed to Panasonic, which discusses a number of issues relating to the installation of television receivers in motor vehicles. The letter notes that NHTSA does not have any safety standards specifical ly covering television receivers. The letter also explains that is possible that the installation of a television receiver could affect the compliance of a vehicle with some safety standards.

With respect to your specific question concerning whether a television receiver installed in view of the driver of a vehicle is required to be off when the ignition is turned on, I would like to draw your attention to one requirement of Standard No. 101, Controls and Displays. Section S5.3.5 of that standard reads as follows:

Any source of illumination within the passenger compartment which is forward of a transverse vertical plane 4.35 inch (110.6 mm) 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 this standard, which is not a telltale, and which is capable of being illuminated while the vehicle is in motion, shall have either (1) light intensity which is manually or automatically adjustable to pr ovide at least two levels of brightness, (2) a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off. This requirement does not apply to buses that are n ormally operated with the passenger compartment illuminated.

The purpose of this requirement is to prevent glare visible to the

driver. If a television receiver installed in view of the driver is capable of operation while the vehicle is in motion, it would be subject to this requirement.

While NHTSA does not have any safety standards specifically covering television receivers, the installation of a television receiver in view of the driver which is capable of operation while the vehicle is in motion would raise obvious safety concerns re lated to possible driver distraction. If you are considering such installation, we recommend that you carefully evaluate the safety implications of such action.

Finally, I note that state laws may cover the installation of television receivers in motor vehicles. The American Association of Motor Vehicle Administrators may be able to provide information on that issue. Its address is: 4200 Wilson Boulevard, Sui te 600, Arlington, Virginia 22203.

Sincerely,