Interpretation ID: 1985-01.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Masaki Ogura -- Manager, Truck Engineering, MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Masaki Ogura Manager, Truck Engineering MMC Services Inc. 3000 Town Center, Suite 501 Southfield, Michigan 48075

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. According to your letter, your trucks, which have a GVWR of more than 10,000 pounds, have a coolant temperature sensor for overheat warning and also a coolant level sensor for lack of engine coolant to prevent engine overheating. Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale. Your letter noted that Standard No. 101 specifies an identifying symbol for coolant temperature but not a symbol for coolant level. You asked whether a system displaying the symbol specified by Standard No. 101 for coolant temperature meets the requirements of the standard. As discussed below, while some of Standard No. 101's requirements are applicable to your trucks, the standard's telltale requirements do not apply to trucks with a GVWR of 10,000 pounds or more.

Section 5, Reguirements, states:

Each passenger car, multipurpose passenger vehicle, truck and bus manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car, multipurpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display. (Emphasis added.)

Thus, Standard No. 101's requirements for identification of controls are applicable to trucks with a GVWR of 10,000 pounds or more, but the standard's requirements for identification of internal displays are not applicable to such vehicles. Since telltales for coolant temperature are a type of internal display, that requirement of Standard No. 101 is not applicable to the vehicles (more than 10,000 pounds) described by your letter.

Sincerely, Jeffrey R. Miller Chief Counsel

December 24,1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: Telltale Identifying Symbol for Coolant; FMVSS No. 101 Controls and Displays

Dear Sir:

This is to inquire about the identifying symbol for engine coolant.

1. Our interpretation is as follows:

In Standard No. 101 the telltale identifying symbol for coolant temperature is specified, but a symbol for coolant level is not specified.

2. Telltale for coolant

Our trucks (more than 10,000 pounds GVWR) have a coolant temperature sensor for overheat warning, and also a coolant level sensor for lack of engine coolant to prevent engine overheat.

Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale for coolant temperature described in FMVSS No. 101 (column 4).

3. Question

Does our system described above conforms to FMVSS No. 101?

Very truly yours,

Masaki Ogura Manager Truck Engineering

MMC SERVICES INC.