Interpretation ID: aiam3154
Safety and Environmental Regulations Department
Renault USA
100 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Louis:#I regret the delay in responding to your lette requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The answers to your specific questions appear below.#*Section 5.2.2*#*Question 1*:Is the expression 'word form' met when using the following abbreviations?#>>>HI for High#LO for Low<<<#*Answer*: The requirement in section 5.2.2 that identification of the heating and air conditioning control shall be in 'word form unless color coding is used' does not preclude the use of readily understandable abbreviations. Therefore, the abbreviations shown above may be used.#*Question 2*: Can we use the arrow symbols corresponding to air directed either on the windshield or the feet for heater and ventilation controls?#*Answer*: Section S5.2.2 of Safety Standard 101-80 states that:#>>>Identification shall be provided for each function of any .... heating and air condition 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, when you speak of directing air on the windshield you are referring to the function performed by a windshield defrosting and defogging system, the control for that system must be identified by use of the symbol shown in Table 1, Column 3 of Safety Standard 101-80. If this is not what you are referring to, any symbol which you use for identification of the control must be accompanied by an identifying word or words or by a readily understood abbreviation or abbreviations unless color coding is used. The same would be true with respect to the identification of a control which directs air from the heater to the feet since Safety Standard 101-80 does not currently specify a symbol for this type of control. Please note, that although section 5.2.2 permits the use of color coding, generally color coding has been used only to identify the extreme positions of a control that regulates temperature over a quantitative range.#*Section 5.3.2*#*Question 1*: What meaning should we give to the expression, 'each discrete and distinct telltale'?#*Answer*: Section 4 of Safety Standard 101-80 defines the word 'telltale' as 'a display that indicates, by means of a light-emitting signal, the actuation of a device, a correct or defective functioning or condition, or a failure to function.' A discrete and distinct telltale is a display that indicates the actuation, correct or defective functioning condition, or a failure to function of *a single* automotive device, system or function.#*Question 2*: Does 'in conjunction' imply that the indicator light and the indicator be joint or directly beside one another?#*Answer*: Safety Standard 101-80 states that: 'any telltale used in conjunction with a gauge need not be identified.' This means that any telltale (what you have referred to as an indicator light) that is an integral part of a gauge (what you have referred to as an indicator) need not be identified. For example, a telltale placed on the fuel gauge to indicate low fuel would not have to be identified by use of the symbol indicated in Table 2 Column 4 of Safety Standard 101-80. However, the gauge itself must be identified by that symbol. If the telltale were placed elsewhere, it would have to be identified by the symbol indicated in Table 2, Column 4.#*Section 5.3.3*#*Question 1*: In this paragraph there is no indication of the number of rheostats required to regulate the luminous intensity of the different instruments.#*Answer*: The number of rheostats to be used is left to the discretion of the manufacturer.#*Question 2*: What is to be understood by 'any illumination that is provided in the passenger compartment'?#*Answer*: This phrase refers to any passenger compartment lighting regardless of its source or purpose, which is activated when and only when the headlights are activated. This interpretation is based upon the language of section 5.3.3 of Safety Standard 101-80 and upon the discussion in the preamble of the notice of proposed rulemaking that proceeded the final promulgation of Safety Standard 101-80. (41 FR 46460, October 21, 1976). The preamble of this notice states that the variable lighting requirements are meant to satisfy the need to enable drivers to reduce glare in the passenger compartment and that their application was expanded in order to include all illumination activated by the headlights 'regardless of whether it shines upon a control [or] display.'#Consequently, such items as a green ring encircling the cigarette lighter, the power window switches and the electric clock encased in the dashboard would be subject to the variable illumination requirements if those items are activated when and only when the headlights are activated.#*Question 3*: Does the phrase 'when and only when the headlights are activated,' include the 'on' parking lamps position of the switch?#*Answer*: This phrase refers only to the situation where the headlight switch is in that position which activates the headlights regardless of what other lights may be activated when the switch is placed in this position. The phrase does not refer to the situation where the headlight switch is in the position which activates only the parking lamps.#*Table 1*#*Question 1*: How must we define 'key locking system' as used in this standard?#Does this expression imply a notion of anti-theft, or does it apply only to a control by key of starting up the engine and/or shutting off the engine without any interaction with an anti-theft locking control on the steering column or the transmission, for example.#*Answer*: The key locking system is the one referred to in section S4.1 of Safety Standard 114. It states that:#>>>Each passenger car shall have a key-locking system that, whenever the key is removed will prevent (a) Normal activation of the car's engine or other main source of motive power, and (b) Either steering or forward self- mobility of the car, or both.<<<#Table 1 of Safety Standard 101- 80 indicates that the identifying words 'engine start' and 'engine stop' must be used when the engine control is separate from the key locking system. These identifying words would have to be used, for example, in a vehicle in which starting or stopping the engine required both insertion or removal of the key and use of a separate control designed to start or stop the engine.#I hope that you will find these responses helpful. If you have any further questions please feel free to address them to Ms. Debra Weiner of my office.#Sincerely, Frank Berndt, Chief Counsel;