Interpretation ID: aiam0344
Product Techniques Section Manager
SAAB-Scania of America
Inc.
100 Waterfront Street
New Haven
CT 06506;
Dear Mr. Taylor:#This is in reply to your petition of March 12, 1971 for amendment of Motor Vehicle Safety Standard No. 101, *Control Location, Identification, and Illumination*.#You petitioned that the abbreviation for the defroster control identification be changed from 'DEF' to 'DEFR.' In the preamble to the reconsideration and amendment of Standard No. 101, (36 F.R. 8269, May 4, 1971), a copy of which I enclose, this agency noted that additional identifying words or symbols are permissible if they do not conflict with the required or permissible words and symbols set out in Standard No. 101. In our opinion your use of 'DEFR' would create no conflict.#You also petitioned that certain controls located below the drivers H point and available to all passengers be exempted from the control identification illumination requirement. The recent amendment to Standard No. 101 no longer required illumination of all heating and air conditioning controls, but only those that direct air directly upon the windshield. We believe this may be responsive to your petition.#Finally, you asked that we define our position on bilingual control identification. Identification in a language other than English is permissible, in the language of the preamble to the recent amendment, 'as long as the additional words . . . do not conflict with the required words . . .'#We hope this answers your questions.#Sincerely, Robert L. Carter, Acting Associate Administrator, Motor Vehicle Programs;