Interpretation ID: aiam2965
Subaru of America
Inc.
7040 Central Highway
Pennesauken
(sic) NJ 08109;
Dear Mr. Utans:#I regret the delay in responding to your September 12 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:#1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its 'no problem' model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.#2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement is section 5.2.3 that the display symbol appear preceptually (sic) upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.#Sincerely, Frank Berndt, Acting Chief Counsel;