Interpretation ID: aiam3538
Jr.
Administration Engineer
Iveco Trucks of North America
Inc.
1730 Walton Road
P. O. Box 1102
Blue Bell
Pennsylvania 19422;
Dear Mr. Pentheny: This responds to your letter asking whether your auxiliary heate toggle switch design meets the identification requirements of Standard No. 101-80, *Controls and Displays*.; By way of background information, I would point out that the agenc does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicle or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. The following interpretation only represent the agency's opinion based on the information provided in your letter.; On the top of the switch is the fan symbol specified by Table 1 of th standard and an arrow pointed upward. When the top of the switch is depressed, the heater fan is activated to recirculate cab air without heating it. On the bottom of the switch is a flame symbol and an arrow pointing downward. When the bottom of the switch is depressed, the heater, including the heater fan, is activated. As explained below, use of the flame symbol for the heater does not meet the identification requirements of Standard No. 101-80.; Section S5.2.2 states: >>>Identification shall be provided for each function of ...*any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. *If this identification is not specified in Tables 1 or 2, it shall be in word form unless color coding is used.* If color coding is used to identify the extreme positions of a temperature control, the hot extreme shall be identified by the color red and the cold extreme by the color blue. [Emphasis added.]; Since the auxiliary heater toggle switch is a heating system control each of its functions must be identified. The switch controls two functions, recirculating air by use of the fan and heating air.; Except for the identification of a heating and/or air conditioning fan neither Tables 1 or 2 specify identification for the functions of a heating system. Therefore, except for a heating and/or air conditioning fan, the functions of a heating system must be identified by words or color coding. I will separately discuss the identification required for the two functions of the auxiliary heater toggle switch.; Depressing the top of the switch activates the fan in order t recirculate air without heating it. This function may be characterized either as recirculation of air or as an on-off switch for the fan. Under the latter characterization, the fan symbol should be used since Table 1 specifies that symbol for a heating and/or air conditioning fan. Thus, the identification on the top of the toggle switch meets the requirements of Standard No. 101-80.; Depressing the bottom of the toggle switch activates both the fan an the heater in order to circulate and heat air. Since neither Table 1 nor Table 2 specify identification for the heating function, it must be in word form. (As explained below, color coding is not appropriate in this instance.) Use of the fan symbol in addition to words identifying the heating function is not necessary, even though the fan operates as part of the heating function, since there is no separate control for the fan. Since the bottom of the toggle switch does not identify the heating function by using words, it does not comply with the requirements of Standard No. 101-80.; In a telephone conversation with Edward Glancy of this office, yo indicated that you desire to use the flame symbol for purposes of international harmonization, noting that is the symbol specified by the ISO for heat. While Standard No. 101-80 specifies a number of other ISO symbols, it does not specify that symbol. Section S5.2.1(a) of the standard does permit the use of additional words or symbols for the purpose of clarity, so long as the words or symbols specified by the standard are used. Thus, you may use the ISO flame symbol if you also identify the bottom of the toggle switch by using words. Since you indicated that you are already producing the vehicles in question, we suggest that you consider simply adding a label with the words 'AUX. HEAT' (or other identifying words) adjacent to the bottom of the toggle switch.; In the above-mentioned telephone conversation, you asked whethe coloring the bottom of the toggle switch red would be considered color coding as that phrase is used in S5.2.2. The answer is no, since the use of any one color by itself does not constitute color coding. We interpret section S5.2.2 (quoted above) to require that color coding must be readily understandable. Although there may be other appropriate uses of color coding, the standard's example of using red and blue to identify the extreme positions of a temperature control is the only one that comes to mind. The use of red for the hot extreme is readily understood only when used in conjunction with blue for the cold extreme.; As you may know, it is the policy of this agency to both promot international harmonization and avoid unnecessary design restrictions. If you wish to produce vehicles using ISO symbols not specified by Standard No. 101-80, you may wish to consider filing a petition for rulemaking on that issue.; Sincerely, Frank Berndt, Chief Counsel