Interpretation ID: aiam3381
Product Manager
Teleflex Industrial Inc. 1816 57th Street
Sarasota
FL 33580;
Dear Mr. Federsel: This responds to your letter of October 8, 1980, in which you requeste an interpretation of Safety Standard No. 127, *Speedometers and Odometers*. You asked us to confirm that your speedometer/odometer meets all the requirements of the rule.; The National Highway Traffic Safety Administration (NHTSA) does no offer prior approval of compliance of any vehicle or equipment design with any safety standard before the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) to determine whether its vehicle or equipment complies with all applicable safety standards and regulations and to certify its vehicle in accordance with that determination.; However, the agency is willing to give an informal opinion concernin whether a vehicle or motor vehicle equipment complies with a particular rule. The speedometer/odometer you sent to us does not comply with the speedometer requirements of Standard No. 127. Section S4.1.4 of that rule requires speedometers to include the number '55' in the mph scale, and to highlight that number in some fashion. There is no '55' on the speedometer you enclose with your letter.; It is not possible to determine upon brief examination whether th odometer meets all the requirements of S4.2.5.2, the encapsulation option. The type of examination necessary to make such a determination is not performed by this agency prior to the manufacturer's certification. It is readily apparent, however, that the odometer you sent to us is in violation of section S4.2.3, as you stated in your letter. The odometer would have to have a sixth wheel or other mechanism to indicate when the number of whole miles or whole kilometers travelled exceeds either 89,999 or 99,999, if the device were to comply with the standard. Note that the effective date of the odometer provisions (sections S4.2 through S5.2) is September 1, 1981. Thus, any odometer that you manufacture prior to that date does not have to comply with the odometer requirements. NHTSA encourages manufacturers to meet these provisions voluntarily, however. The speedometer requirements (section S4.1) of Standard No. 127 are presently in effect, and thus all speedometers you manufacture must currently be in compliance.; We emphasize that the above statements are only the agency's opinio based on the information you have supplied, and that opinion is not binding on you or the agency. It is your duty as the manufacturer to determine whether in fact your product meets the requirements of the standard and to certify that compliance. We hope you find this information helpful. Please contact this office if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel