Interpretation ID: 1985-02.21

TYPE: INTERPRETATION-NHTSA

DATE: 04/29/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Wataru Hayashibara -- Manager, Certification Business Division, Mazda Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Wataru Hayashibara Manager Certification Business Division Mazda Motor Corporation P.O. Box 18, Hiroshima, 730-91 Japan

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. According to your letter, you are considering a bulb check system for telltales that operates while the ignition switch is turned to the "ON" position and the engine is not running. You stated that the proposed design of this system is such that all telltales subjected to the bulb check may emit light simultaneously when any malfunction occurs in the electrical charging system. You asked whether the proposed system would comply with the requirements of section S5.3.1 of the standard. You also asked whether the answer is dependent on whether a vehicle is equipped with a telltale for electrical charge. As discussed below, the answer to both of your questions is no.

By way of background information, this agency does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.

Section S5.3.1 of Standard No. 101 states:

A telltale shall not emit light except when identifying the malfunction or vehicle condition for whose indication it is designed or during a bulb check upon vehicle starting.

There are thus only two situations in which it is permissible for a telltale to emit light: (1) when the telltale is actually identifying the malfunction or vehicle condition for which it is designed, and (2) during a bulb check upon vehicle starting. The emitting of light by all telltales whenever a malfunction occurs in the electrical charging system does not fall within either of these categories and is therefore not permitted by the standard.

This interpretation is limited to the specific factual situation described above, i.e., where light would be emitted by all telltales whenever a malfunction occurs in the electrical charging system. In essence, your proposed design would replace the telltale for electrical charge, which is provided by most manufacturers to warn of such things as low voltage, with a warning message in the form of all telltales simultaneously emitting light. This is not permitted by Standard No. 101, for the reasons stated above.

Your letter suggests an interpretation that the simultaneous lighting of all telltales subjected to the bulb check when any malfunction occurs in the electrical charging system could not be any violation of the requirements of S5.3.1, because it is the vehicle condition which "is designed" by a manufacturer for all telltales to emit light. We do not agree with that suggested interpretation. Section S5.3.1's use of the words "malfunction or vehicle condition for whose indication it is designed" refers back to the term "(a) telltale." It is our opinion that the phrase is applicable only to the specific malfunction or vehicle condition for which a particular telltale is designed to warn the driver and not to a situation where all telltales are designed to collectively warn of a malfunction or vehicle condition.

Our interpretation is not dependent on whether a vehicle is equipped with a telltale for electrical charge or not.

Sincerely,

Jeffrey R. Miller Chief Counsel

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

December 26, 1980 Our Ref. No. NH84/20

Re: Request for Interpretation of FMVSS 101 Controls and Displays

Dear Mr. Berndt:

This is to request your interpretation regarding the telltale lighting condition specified in the last sentence, shown below, of S5.3.1 of Standards No. 101.

"A telltale shall not emit light except when identifying the malfunction or vehicle condition for whose indication it is designed or during a bulb check upon vehicle starting."

(Underline is added.)

We are now studying a bulb check system that operates while the ignition switch is turned to "ON" position and the engine is not running. If this system is adopted, all telltales subjected to the bulb check may emit light simultaneously when any malfunction occurs in the electrical charging system.

Under the above-mentioned conditions, we would like to have your confirmation whether the following interpretation is correct.

The simultaneous lighting of all telltales subjected to the bulb check when any malfunction occurs in the electrical charging system could not be any violation of the requirements of S5.3.1, because it is the vehicle condition which "is designed" for all telltales to emit light by a manufacturer.

If the interpretation depends on whether a vehicle is equipped with "a telltale for electrical charge" or not, the interpretations in both cases would be appreciated.

Your prompt interpretation on this matter would be appreciated.

Sincerely yours,

Wataru Hayashibara Manager Certification Business Division

cc: Mazda (North America), Inc. Mazda (North America), Inc. Detroit Office