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Interpretation ID: aiam0939

Mr. James Tydings, Chief Engineer, Thomas Built Buses, Inc., 1408 Courtesy Road, P. O. Box 1849, High Point, NC 27261; Mr. James Tydings
Chief Engineer
Thomas Built Buses
Inc.
1408 Courtesy Road
P. O. Box 1849
High Point
NC 27261;

Dear Mr. Tydings:#This is in response to your recent inquiries t Berkley Sweet concerning Federal Motor Vehicle Safety Standards Nos. 101 and 108.#You ask whether S4.2.2 of Standard No. 101 applies to push-pull switches. This paragraph requires identification for the extreme positions of any heating and air conditioning system control that regulates a function over a quantitative range, and you state that you currently do not indicate the quantitative range for the heater switches.#S4.2.2 does apply to push-pull switches, and I enclose a notice that the agency published on December 3, 1971, clarifying our intent. A legend such as 'push off' and 'pull high' would be sufficient to meet the requirements of Standard No. 101. You would not have to redesign your switch cabinet to provide a slide or lever-type switch.#You also asked whether the school bus lighting description on your attached pages numbered 34 and 35 is 'legal'. The system as described conforms to the requirements of Standard No. 108 for the items listed.#Sincerely, Richard B. Dyson, Assistant Chief Counsel;