Interpretation ID: 7418-2
Southam Drive
Kineton Road Industrial Estate
Southam, Leamington Spa,
Warwickshire, CV33 OFA England
Dear Mr. Buttle:
This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You requested clarification of the standard's requirement that certain information be displayed "in view of the driver." You also asked whether the display must be permanently illuminated. Your questions are responded to below.
By way of background information, the National Highway Traffic Safety Administration 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 standards. The following represents our opinion based on the facts provided in your letter.
For vehicles with automatic transmissions, Standard No. 102 requires that identification of shift lever positions, including the positions in relation to each other and the position selected, must be displayed "in view of the driver" at specified times. See S3.1.4 through S3.1.4.4. For vehicles with manual transmissions, the standard requires that identification of the shift lever pattern of manual transmissions, except three forward speed manual transmissions having the standard "H" pattern, must be displayed "in view of the driver" at specified times. See S3.2.
You stated that you believe that the requirement for certain information to be displayed "in view of the driver" relates to the 95 percent eye range contour, hence requiring a display on or near to the "instrument binacle." You asked whether this is correct, or whether floor shift identification is sufficient.
NHTSA has previously addressed Standard No. 102's requirement that certain information be displayed "in view of the driver" in connection with a request for interpretation concerning the identification of the shift lever pattern of manual transmissions. The agency concluded that the pattern "is deemed to be `displayed in view of the driver' if part of it may be seen from the driver's normal eye position and a reasonable amount of movement of the driver allows him to gain full view of the pattern." (Letter to Daimler-Benz of North America, February 27, 1967.) Thus, the information required by Standard No. 102 to be displayed in view of the driver may be displayed on the instrument panel, floor console, or other locations, so long as these criteria are satisfied.
Your second question asked whether the information required to be displayed by Standard No. 102 must be permanently illuminated for night usage. You stated that some auto makers have made this facility switchable.
NHTSA's requirements concerning the illumination of motor vehicle controls and displays are set forth in Standard No. 101, Controls and Displays. S5.3.1 of the standard requires that if a gauge is listed in column 1 of Table 2 and accompanied by the word "yes" in column 5, then the gauge and its identification must be illuminated whenever the ignition switch and/or the headlamps are activated. The last gauge listed in Table 2 is "automatic gear position," and the word "yes" appears in column 5. Therefore, automatic gear position gauges, i.e., the gauges which provide the information required by Standard No. 102 to be displayed for automatic transmission vehicles, are subject to Standard No. 101's illumination requirement.
Under S5.3.3 of Standard No. 101, an automatic gear position gauge may have levels of brightness at which the gauge and its identification are not visible. It is common, for example, for manufacturers to provide a variable light intensity control that enables the driver to turn the illumination for conventional automatic gear position gauges down to off.
It is important, however, to distinguish between turning the illumination off i.e., no illunimation, but display still visible, and adjusting the gauge itself in a way that it no longer displays the required information. As indicated above, Standard No. 102 requires that certain gear position information be displayed in view of the driver at specified times. This requirement would not be met if it were possible for the driver to adjust the automatic gear position gauge in a way that it no longer displayed the required information during the specified times. An example of this would be an electronic gauge using light emitting diodes, where the driver, while driving, could turn the electronic display down to the off level. In this instance, the gauge would not be displaying the required information.
I hope this responds to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:101#102 d:8/13/92