Interpretation ID: aiam2870
Manager
Certification Department
American Honda Motor Co.
Inc.
P.O. Box 50
Gardena
California 90247;
Dear Mr. Gill: This is in reply to your letter of August 24, 1978, asking for a interpretation of Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*. Specifically, you have asked whether Honda's proposed manual fuel shutoff control design would comply with the standard. In this proposed design, in your word 'a second 'Off' position will be provided 180 degrees from the required position.'; Standard No. 123 requires the manual fuel shutoff control to b 'operable as specified in Column 3 [of Table 1]' (S5.2.1). Table 1 specifies that the 'Off' position is with the 'control forward.' Although the control in your proposed design shuts the fuel valve when pointed forward, it also shuts the valve at a position 180 degrees from the complying one, with the 'control backward,' so to speak. Thus, the control is not 'operable as specified' within the meaning of the requirement.; As you know, the safety purpose of standardization of control locatio and operation is to insure that the novice cyclist, and those who change cycles frequently, are not confused when controls must be operated under emergency conditions. Since your proposed control design is operable both forward and backward it does not comply with Standard No. 123.; Sincerely, Joseph J. Levin, Jr., Chief Counsel