Interpretation ID: 1982-1.37

TYPE: INTERPRETATION-NHTSA

DATE: 03/31/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sheller-Globe Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION NOA-30

Mr. Dick Premo Superior Division Sheller-Globe Corporation 1200 East Kibby Lima, Ohio 45802

Dear Mr. Premo:

This responds to your telephone call of March 10, 1981, asking about Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked two questions about the requirements applicable to a vehicle which is completed as a school bus: (1) What symbol or words must be used to identify the controls of a heater which is placed in a vehicle, either next to a door or in the rear of the vehicle, for the purpose of providing heating capability in addition to that provided by the vehicle's primary heating system, and (2) what symbol or words must be used to identify the controls of a fan which is mounted along a vehicle is instrument panel for the purpose of providing defogging capability in addition to that provided by the vehicle's primary defrosting/defogging system. You stated that the controls for both the additional heaters and the fan are located on a panel mounted on the vehicle 's engine cover, next to the driver, and that the controls are illuminated.

Both the heaters and the fan must be identified as provided in Standard No. 101. Section S5 of Standard No. 101 states that each vehicle that is subject to the standard and is manufactured with any control listed in Section S5.1 or in column 1 of Table 1 must comply with the requirements of the standard regarding the location, identification and illumination of such controls. Controls for both heating systems and defrosting/defogging systems are listed in column 1 of Table 1. Since the additional heaters" comprise part of the completed vehicle's heating system and the fan comprises part of the completed vehicle 's defogging system, the controls for those devices are subject to Standard No. 101's requirements.

I will first discuss the requirements for the heater controls. If the heater has a fan for which there is a control, it must be identified by the symbol specified in Table 1 of the standard. Identification must be provided for each function of any heating system control and for the extreme positions of any such control that regulates a function over a quantitative range. The standard does not specify the means of such identification other than to require that it be in word form unless color coding is used. Also, if color coding is used to identify the extreme positions of a temperature control, the standard specifies that the hot extreme shall be identified by the color red and the cold extreme by the color blue.

Section S5.2.1 states:

. . .any hand operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol. Such a control may, in addition, be identified by the word or abbreviation shown in column 2. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification shall be placed on or adjacent to the control. . . Neither a symbol nor identifying words are listed in Table 1 for the controls of a heating system, with the exception of the control for a heating fan.

Section S5.2.2 states:

Identification shall be provided for each function of . . .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.

The requirements for the defogging fan are simpler. Table 1 does specify a symbol for a defrosting/defogging system. Since the fan constitutes a part of the completed vehicle' s defogging system, that symbol must be used to identify the control.

While it is not required by the standard, we suggest that you use words in addition to the symbol to indicate that the fan is for the purpose of providing defogging capability in addition to that provided by the vehicle's primary defrosting/defogging system. For example, you might use the words "Auxilliary Defog" or "Aux. Defog." The use of such words in addition to the symbol would help prevent a driver seeing the control identification from incorrectly concluding that the control operated the vehicle's primary defrosting/defogging system.

Sincerely, Frank Berndt Chief Counsel