Interpretation ID: 1985-03.2

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/85 EST

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TITLE: FMVSS INTERPRETATION

TEXT:

Subject: Petition for Reconsideration of FMVSS 101; Controls and Displays

The Daimler-Benz AG (DBAG) Petition for Reconsideration dated August 22, 1984 was denied. The rationale behind the Agency's decision for denial was that DBAG did not adequately address the concerns raised in the Preamble to the final rule of July 27, 1984.

Daimler-Benz AG respectfully petitions the Agency to reconsider its decision in view of the following:

1. Horn Control Symbol:

While we concur with some of the arguments set out by the Agency, we would like to draw attention to the importance of the driver's responsibilities. This would respond to the Agency's concern that certain drivers may have difficulties in locating the horn control in an emergency situation when manufacturers place the horn control in areas other than the traditional location in the steering wheel hub.

Location of controls and displays is specified in paragraph S5.1 of FMVSS 101 in that each required control and display must be visible (when activated) to a driver who is restrained by the crash protection provisions required by FMVSS 208.

From the above it follows that the location of control and displays - even if identified by symbol or words - may vary significantly between manufacturers or even models.

Examples:

- The windshield washer and wiper control may be located either on the right or left side of the steering column and may or may not be combined with the turn signal control.

- The hazard warning signal control may be found anywhere on the dashboard, the steering column or the transmission tunnel.

- Lights may be activated by dashboard controls or separate stalks.

- Even gear shift patterns may be varying.

DBAG firmly believes that the identification of controls by symbols or words can only assist either to distinguish between otherwise similar controls or to locate their position if there is sufficient time left for searching. It will not, however, produce shorter driver reaction times in situations where he is required by circumstances beyond his control, to act immediately and intuitively as long as he is not aware of the general location and operating direction of any one control.

Hence, it follows that it is imperative for a driver, prior to using a car that he is not familiar with, to verify the location and function of every control and display, if necessary with the aid of the owner's manual. If he fails to undergo this learning process it must be assumed that he will also fail to correctly operate the appropriate control in a critical moment - regardless of whether or not that control is labeled.

The above considerations lead us to be convinced that the main distinctive features of the most essential controls in a car - as far as the problem of intuitive operation is addressed - are the variations in location, operating direction and shape, rather than their marking with different symbols. Yet, we would not go so far as to request that the hitherto required control symbols be omitted provided such distinctive features are maintained. We feel, however, that a horn control in such a prominent location as in the steering wheel hub - i.e. closest to either hand of the driver -, with such a simple and unequivocal operating mode -i.e. pressing of a usually adequately large area - can, even if not identified by a symbol, be at least as safely and intuitively operated as any other customary control having a symbol.

On the grounds explained above, DBAG reiterates its petition that the exemption of horn control identification be extended and footnote 4 to table 1 be modified to read: "provided there are no other controls incorporated, identification is not required for horn controls in, or on, the steering wheel hub, or for narrow ring-type controls and air-horns".

2. Brake Symbol

Our request to permit the ISO brake failure symbol has also been denied by the Agency. We would like to comment on the arguments presented in the June 4, 1985 Federal Register as follows:

The rationale of adopting certain ISO symbols, according to the NPRM of November 4, 1982, is that they convey information more quickly and are easily and immediately recognizable. DBAG fully supports this opinion. On the other hand, the Agency mentions the results of a SAE investigation, according to which the percentage of recognition of the ISO brake symbol is only 26 and 21 per cent, respectively, vs. 87 and 52 per cent, respectively, of the word "Brake". This leads the Agency to conclude that it is not appropriate to adopt this particular ISO symbol.

However, in order to fully appreciate the meaning of the above-mentioned percentages, it has to be kept in mind that the ISO brake symbol has not been permitted in the USA so far. Therefore, it is to be assumed that the persons interviewed by the SAE have been confronted with a symbol that they had never seen before. Given this fact, a 21-26 percent recognition of statement and function is not, as the Agency suggests, "extremely low", but has, in fact, to be considered as remarkably high.

Moreover, we would like to emphasize that there is a very strong general trend to replace words by symbols or pictograms, e.g. in public buildings, airports, railway stations, etc. It can be stated that people become very quickly accustomed to such symbols and pictograms even if they are not internationally standardized.

For this reason, we again petition to permit the use of the ISO brake failure symbol instead of the word "Brake".