Interpretation ID: 1983-2.13

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/83

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Volvo White Truck Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 27 1983 NOA-30

Mr. J. W. Lawrence Manager, Compliance and Recall Volvo White Truck Corporation P.O. Box D-1 Greensboro, NC 27402-1200

Dear Mr. Lawrence:

This responds to your letter concerning Safety Standard No. 101, Controls and Displays. You asked whether standard's identification and illumination requirements are applicable to an optional windshield wiper control you are planning to make available on some heavy duty trucks.

By way of background information, the agency does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is up to the manufacturer to assure that its vehicles and equipment comply with applicable Federal motor vehicle safety standards. The following interpretation represents our opinion based on the facts provided in your letter. It also takes into account information provided in a follow-up telephone conversation with Edward Glancy of this office.

The standard wiper controls for the vehicles in question consist of two knobs which independently control the left and right wipers. These controls provide both the on-off function and variable speed. According to your letter, these controls are identified and illuminated as required by the standard.

The proposed optional control, the specific subject of your letter, would provide a time delay for windshield wiper operation during light mist conditions. The control would be a knob which, if turned to the left, would provide no pause, and if turned toward the right, would offer a variable time delay.

We are unable to agree with your suggestion that the control is not covered by Standard No. 101. As discussed below, Standard No. 101 requires that this control, like the standard controls, be identified and illuminated in accordance with the standard's requirements. Additional words or symbols may be provided for the purpose of clarity.

Section S5 of Standard No. 101 requires, among other things, that each truck manufactured with any control listed in S5.1 or in column 1 of Table 1 meet the requirements of the standard for the location, identification, and illumination of such control. One of the controls listed by S5.1 is "windshield wiper." Also, "windshield wiping system" is among the controls listed in column 1 of Table 1. The issue raised by your letter is therefore whether an optional control for intermittent wiper operation is within the meaning of "windshield wiper" control and/or "windshield wiping system" control. It is our interpretation that such a control is within the meaning of both terms.

Neither the term "windshield wiper" control nor "windshield wiping system" control is limited to specific wiper functions, such as on-off, variable speed, etc. Since a control for intermittent wiper operation controls one function of windshield wipers, it is a "windshield wiper" control or "windshield wiping system" control. Such a control is therefore subject to the standard's requirements for location, identification and illumination.

We would note that while section S5.2.1 and Table 1 require such a control to be identified by the symbol specified for windshield wiping system controls, additional words or symbols may be used at the manufacturer's discretion for purposes of clarity. Since your vehicles would have three windshield wiper controls, you may wish to provide such additional words or symbols to explain the function of each.

Sincerely,

Frank Berndt Chief Counsel

March 30, 1983

Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

Subject: Request for Interpretation FMVSS-101 Controls and Displays

Volvo White Truck Corporation of Greensboro, North Carolina, a manufacturer of heavy duty trucks 26,000 lbs. and greater GVWR, requests an interpretation of FMVSS-101 as it applies to these classes of vehicles. In specific, we request an interpretation of S 5.3.1 and Table 1 for an optional windshield wiper control available on some of our vehicles.

Volvo White's standard wiper controls are identified and illuminated as required by S 5.3.1 and Table 1 of the Standard. We also are making available an additional control that allows the driver to "time" the wiper sweep by delaying the wipe cycle for vehicle operation during light mist conditions. The control is separate from the wiper control and selects only the desired time delay for the intermittent wiper operation.

Considering that this control operates the time delay feature only but is similar to a wiper control, Volvo White considers it should be identified as follows:

1. The control is not covered by Standard 101, therefore, the identification is at the discretion of the manufacturer.

2. Standard 101 does not prohibit the use of the symbols in Table I for similar type controls. Volvo White may use the symbols and/or words in Table I or other appropriate identification.

3. The control, when mounted on the instrument panel may, but need not, be illuminated.

Volvo White would appreciate, at your earliest convenience, confirmation or clarification on the three issues noted above.

Very truly yours,

J. W. Lawrence Manager, Compliance and Recall