Interpretation ID: 77-5.20

TYPE: INTERPRETATION-NHTSA

DATE: 12/30/77

FROM: AUTHOR UNAVAILABLE; S. P. Wood for J. J. Levin, Jr.; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 4, 1977 letter asking whether Standard No. 118 Power-Operated Window Systems, prohibits the operation of power windows when the ignition key is in the "Accessories" position.

Standard No. 118 requires only that power windows be inoperable when the key is in the "off" position or is removed from the lock, with certain exceptions outlined in S3. It is permissible for the windows to operate normally when the key is in the "Accessories" position.

SINCERELY,

NISSAN MOTOR CO., LTD.

October 4, 1977

Joseph J. Levin Office of the Chief Counsel NHTSA

This letter is to ask for your interpretation concerning FMVSS 118 "Power-operated Window Systems".

S.3 of that standard requires that no power-operated window or partition shall be movable when the ignition key is in an off position or is removed from the lock.

In the case of the 5-position ignition switch as shown in the attachment, should the power-operated windows not be movable when the ignition key is in an "Acc" (Accessories) position?

Thank you for your attention to the above matter. We look forward to hearing your reply of the above in the near future.

Tokio Iinuma Staff Safety -- ENGINEERING OFC. OF NORTH AMERICA

Ignition switch

The 5-position ignition switch is located on the right side of the steering column. The switch includes the antitheft steering lock device and also controls the ignition system and most of the electrical equipment:

"LOCK" Normal parking position The ignition key can be inserted and removed at the "LOCK" position only. The steering can be locked by turning the key to the "LOCK" position, removing it, and rotating the steering wheel until the locking plunger clicks into position.

To unlock the steering, insert the key and turn it to the "OFF" position. For easier key operation when unlocking, rotate the steering wheel slightly to relieve pressure on the steering lock.

"OFF"

This position permits turning the engine off without locking the steering wheel.

"ACC" (Accessories)

This position allows you to use all the electrical accessories controlled by the switch.

"ON" Normal operating position

This position turns on the ignition system and electrical circuits.

"START"

This position starts the engine. After the engine has started, release the key. It will automatically return to the "ON" position.

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