Interpretation ID: aiam3928
Manager
Engineering
Isuzu Motors America
Inc.
21415 Civic Center Drive
Southfield
MI 48076;
Dear M. Tokunaga: This responds to your letter concerning an amendment to Federal Moto Vehicle Safety Standard No. 101, *Controls and Displays*, which became effective on an optional basis on July 27, 1984, and becomes effective on a mandatory basis on September 1, 1987. The answers to your questions are provided below.; By way of background information, this agency does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; Your first question asked about the identification requirements for headlamp beam control that is separate from the master lighting switch. You asked how such a control should be identified and whether it is subject to the standard's identification requirements if it controls only the headlamps and not the taillamps. As discussed below, such a control should be identified by either identifying word or identifying symbol, whether or not the headlamp beam control operates the taillamps. The specific word or symbol is at the option of the manufacturer. Additional words or symbols may be provided for purposes of clarity at the discretion of the manufacturer.; Section S5.2.1 states in relevant part: >>>Vehicle controls shall be identified as follows: (a) ... any hand operated control listed in column 1 of Table 1 tha has a symbol designated in column 3 shall be identified by that symbol. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2, if such word abbreviation is shown. Words or symbols in addition to the required symbol, word or abbreviation may be used at the manufacturer's discretion for the purpose of clarity. Any such control for which column 2 of Table 1 and/or column 3 of Table 1 specifies 'Mfr. Option' shall be identified by the manufacturer's choice of a symbol, word or abbreviation, as indicated by that specification in column 2 and/or column 3. The identification shall be placed on or adjacent to the control. The identification shall, under the conditions of S6, be visible to the driver and, except as provided in S5.2.1.1 and S5.2.1.2, appear to the driver perceptually upright.<<<; As your letter noted, controls for 'Headlamps and Taillamps' are amon those listed in column 1 of Table 1. That table specifies that identifying words or abbreviations or identifying symbols are at the manufacturer's option, and includes a footnote stating that separate identification is not required if those lamps are controlled by a master lighting switch. It is our opinion that the term 'Headlamps and Taillamps' includes controls which operate only the headlamps. Therefore, identification in the form of word or symbol must be provided for such a control; Your second question asked about the identification requirements for master lighting switch control for which there are three positions. In the first position, all lights are off, in the second position, all lights are on except for the headlamps, and in the third position, all lights are on. Your question was asked in reference to a drawing showing two types of switches (with two proposed methods of identification for each switch). The first type of switch, which you referred to as a push button switch, consists of three buttons directly adjacent to one another. The second type of switch, which you referred to as a rotary switch, consist of a switch at the end of a stalk, which rotates about the axis of the stalk to provide the three positions. You asked about two alternative interpretations concerning the identification requirements for these controls: (1) whether the master lighting switch symbol must be indicated in the position of the headlamp mode or (2) whether it is instead permissible to use the optional headlamp and taillamp symbol given in Table 1(a) provided that the master lighting switch symbol is affixed nearby. As discussed below, the master lighting switch symbol need not be indicated in the position of the headlamp mode so long as that symbol is on or adjacent to the switch.; Section S5.2.1, quoted above with respect to your first question, i also relevant to this question. Master lighting switches are among the controls listed in column 1 of Table 1, and an identifying symbol is specified by column 3. Under section S5.2.1, therefore, manufacturers must identify master lighting switches by the specified symbol and place the symbol on or adjacent to the master lighting switch. It is our opinion that each of the designs discussed by your letter represents one mater lighting switch, with three positions. Standard No. 101 permits the specified symbol to be placed anywhere on or adjacent to the master lighting switch and does not require the placement of the symbol to indicate the position of the headlamps mode. Manufacturers are not required to provide any identification other than the specified symbol for master lighting switch, it is our opinion that all four designs would be permitted by the standard.; Sincerely, Jeffrey R. Miller, Chief Counsel