Interpretation ID: aiam0414
Jr.
Group Supervisor
Engineering Services
Blue Bird Body Company
Fort Valley
GA 31030;
Dear Mr. Phelps:#This is in reply to your letter of July 7 askin whether paragraph S4.2 of Standard No. 101 requires labeling of 'a heater water valve near the floor in the driver's area.'#As you know, Standard No. 101 requires identification of heating and air conditioning controls that are manually operable and mounted in a location other than on the floor. Your heater water valve is manually operable and not floor mounted, and it is our opinion that Standard No. 101 requires its identification. This agency published an interpretation on May 4, 1971, copy enclosed (see p. 8297), in response to a query from Ford 'whether controls visible to the driver but not in the normal forward line of sight must be identified.' We replied in the affirmative that although controls may be 'designed to be operable by touch, their function is not clear to an operator unfamiliar with the vehicle in which they are installed, and their identification is necessary.' For the same reason paragraph S4.2 of Standard No. 101 requires identification of your heater water valve control.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel;