Interpretation ID: aiam4131
Engineering
Federal Motors Inc.
P.O. Box 5000
Ocala
FL 32678;
Dear Mr. Demski: This responds to your request for an interpretation of Federal Moto Vehicle Safety Standard (FMVSS) No 101, *Controls and Displays*. You asked about the identification requirements applicable to a coolant temperature telltale. According to your letter and an accompanying drawing, you are currently identifying the telltale with the identifying symbol for the coolant temperature telltale specified by Table 2 of FMVSS No. 101, and the words 'ENG WATER TEMP'. Noting that some of your vehicles have engines which are air-cooled rather than water-cooled, you asked if FMVSS No. 101 permits you to delete the word 'WATER' while otherwise continuing to identify the telltale as described above. As discussed below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, the manufacturer has the responsibility to certify that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; Section S5.2.3 of FMVSS No. 101 states in relevant part: >>>Except for informational readout displays, any display locate within the passenger compartment and listed in column 1 of Table 2 that has a symbol designated in column 4, shall be identified by that symbol. Such display may, in addition be identified by the word or abbreviation shown in column 3. . . . Informational readout displays may be identified by the symbol designated in column 4 of Table 2 or by the word or abbreviation shown in column 3. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. . . .<<<; The coolant temperature telltale is a display listed in Table 2 o FMVSS No. 101, and the symbol pictured in your letter is the identifying symbol for that telltale specified in column 4 of the table. Therefore, under section S5.2.3 of the standard, your use of that symbol to identify the coolant temperature telltale is sufficient identification regardless of what, if any, identifying words you provide for the purpose of clarity.; Sincerely, Erika Z. Jones, Chief Counsel