Interpretation ID: aiam2271
President
Norton Triumph Corporation
P.O. Box 275
Duarte
California 91010;
Dear Mr. Stange: This is in reply to your letter of April 1, 1976, which requests a interpretation of Motor Vehicle Safety Standard No. 123 as it applies to a motor-driven cycle that your company intends to import.; "The speedometer on this machine displays both minor numerals and mino graduations at 5 mph intervals. Paragraph S5.2.3 and Column 3 of Table 3 of Standard No. 123 require that, if a motorcycle is equipped with a speedometer, 'Major graduations and numerals shall appear at 10 mph intervals, minor graduations at 5 mph intervals.' S5.2.3 also states that the abbreviations used in Column 2 and 3 are j minimum requirements and 'appropriate word may be spelled in full.' It is your interpretation that 'if the abbreviations used in Column 3 are minimum requirements ... the speedometer in question meets the minimum requirements and is therefore in conformity with the standard.'"; The 'abbreviations' only refer to words and not to numerals o graduations. However, since there is no specific prohibition against providing minor numerals at the minor graduations, we have concluded that Standard No. 123 allows a motorcycle manufacturer to furnish a speedometer with them if he so chooses.; Yours truly, Stephen P. wood, Assistant Chief Counsel