Interpretation ID: aiam3135
Technical Representative - Safety
Engineering Office of North America
Nissan Motor Co.
Ltd.
1919 Pennsylvania Ave.
N.W.
Suite 707
P.O. Box 57105
Washington
DC 20037;
Dear Mr. Murakami:#This is in response to your letter of September 14 1979, in which you asked about the applicability of the variable intensity illumination requirements of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*, to various components in your company's automobiles. You listed and identified these parts in Figure 1 of your letter which I will refer to in answering your questions.#The variable intensity illumination requirements of section 5.3.3 of Safety Standard 101-80 are applicable to (1) 'controls, gauges, and their identification,' and to (2) 'any illumination that is provided in the passenger compartment when and only when the headlights are activated.' As noted in section 5 of Safety Standard 101-80, the location, identification, and illumination requirements are applicable only to passenger cars and other vehicles equipped with any control listed in section 5.1 or in column 1 of Table 1. The term 'gauge' is defined in Section 4 as a 'display that is listed in section 5.1 or in Table 2 and is not a telltale.'#Applying these criteria to the list of automobile components in your letter, I have concluded that none of the listed components, except the ordinary clock and the automatic gear position illumination lamp, are subject to the requirements of Section 5.3.3 of Safety Standard 101-80. Since this result resolves the issues raised in Questions Q2.1 - Q2.5 of your letter, I have not addressed them in this response.#The components identified in your diagram by letters a - h (the room lamp, spot lamp, luggage room lamp, personal lamp, radio, foot lamp, step lamp, and the luggage room lamp for hatchback vehicles) are not subject to the requirements of section 5.3.3. This is because they are not controls listed in section 5.1 or in column 1 of Table 1 of Safety Standard 101-80 and because they do not illuminate the passenger compartment when and only when the headlights are activated. Similarly the glove box lamp and the console box lamp (items i and j) are not subject to section 5.3.3. They are not controls listed in Safety Standard 101-80 and they are not activated when and only when the headlights are activated since their activation requires both opening the box lids and switching on the headlights.#The ignition key illumination lamp (item k), which is not a control listed in Safety Standard 101-80, is activated when the light control switch is turned to the 'small lights only' position (this activates the clearance clamps (sic), identification lamps, and other exterior lamps other than the headlights.) When the switch is turned to the position that activates both, the small lights and the headlights, the key illumination lamp is deactivated. Consequently, the lamp is not activated when and only when the headlights are activated and is, therefore, not subject to the variable intensity illumination requirements.#You noted in conversation with Ms. Debra Weiner of my office that your company uses two types of clocks (item 1 in your letter) in its automobiles. One is an ordinary clock whose face is illuminated when and only when the headlights are activated. The requirements of section 5.3.5 would apply to the illumination of this type of clock.#The other clock used in your company's automobiles is a digital clock with a flourescent (sic) readout which shines with greater intensity during the day and with a lower intensity at night when the headlights are activated. Since this clock is not a control or a display listed in Safety Standard 101-80 and its illumination is not activated when and only when the headlamps are activated, the requirements of section 5.3.3 for continuously variable illumination are not applicable. Section 5.3.3 also provides that light intensity for informational readout systems shall have at least two values. The term 'informational readout systems' which is not defined in Safety Standard 101-80 refers to the term 'informational readout display,' which is defined as 'a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed.' The term 'display' includes only those displays listed in section 5.1 or in column 1 of Table 2 of the standard and these listings do not include a digital clock. Therefore, the digital clock would not be subject to the light intensity requirements for informational readout systems.#The automatic gear position illumination lamp (item m in your letter) is subject to the variable intensity illumination requirements of section 5.3.3. Although it is not a control (see preamble to Safety Standard 101-80, 43 FR 27541, June 26, 1978) this lamp is activated when and only when the headlights are activated.#In Question 2 of your letter, you asked for the definition of the terms 'continuously variable' and 'variable.' The term 'continuously variable' is defined in section 5.3.3(a) and (b) of Safety Standard 101-80. It is followed by a description of the two light intensities which must be provided for informational readout systems. The term 'variable' appears in the next sentence in section 5.3.3 which states that:#>>>'The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated *shall also be variable in a manner that complies with this paragraph*. (sic)<<<#The underlined words in the quoted sentence refer to the definition of 'continuously variable' except in the case of informational readout displays where the words refer to illumination of two intensities.#If you have any further questions, I will be happy to answer them.#Sincerely, Frank Berndt, Chief Counsel;