Interpretation ID: aiam3461
Manager
Certification Department
American Honda Motor Co.
Inc.
P.O. Box 50
100 W. Alondra Blvd.
Gardena
California 90247;
Dear Mr. Gill: This responds to your letter of July 27, 1981, asking about Federa Motor Vehicle Safety Standard No. 101-80. Your letter asked whether an enclosed sample of a heater control identification plate met the requirements of section S5.2.2 of the standard. Your letter was primarily concerned about whether the color used for the hot extreme would be considered 'red' within the meaning of that section.; The sample heater control identification plate enclosed with you letter identifies the hot an cold extremes of the temperature control by both words and color. At the left of the identification plate is the word 'cold' on a blue background. At the right of the identification plate is the word 'hot' on a background that appears by visual inspection to be orange.; Section S5.2.2 of Standard No. 101-80 states: >>>Identification shall be provided for each function of any automati vehicle speed system control an any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. If this identification is not specified in Tables 1 or 2, it *shall be in word form unless color coding is used*. If color coding is used to identify the extreme positions of a temperature control, the hot extreme shall be identified by the color red and the cold extreme by the color blue . . . . [Emphasis added.]<<<; The agency interprets section S5.2.2 to require that the colors red an blue be used to identify the extreme positions of a temperature control only when color is the sole means by which the extreme positions are identified. If the words 'hot' and 'cold' are used to identify the extreme positions, color coding is a voluntary addition and the red and blue color requirements of section S5.2.2 do not apply.; Therefore, since the sample of the heater control identification plat enclosed with your letter identifies the extreme positions of the temperature control with the words 'hot' and 'cold,' it meets the requirements of section S5.2.2 concerning that requirement regardless of whether the color used for the hot extreme would be considered 'red' within the meaning of that section.; As to your question whether the color used for the hot extreme on th sample of the heater control identification plate is red, our visual inspection indicates that the color is orange rather than red. For guidance on the meaning of the color 'red,' we suggest that you refer to 49 CFR S172.407(d). That section, which is part of the Departments of Transportation's regulations concerning hazardous materials, establishes color tolerances for various colors, including red. The section indicates how to obtain copies of the Department's color tolerance charts or where they may be inspected. While the charts are not referenced by Standard No 101-80, they do provide guidance on the tolerances of various colors.; Sincerely, Frank Berndt, Chief Counsel