Interpretation ID: nht76-1.3

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to American Motors Corporation's (AMC's) September 9, 1976, request for confirmation that Standard No. 101, Control Location, Identification, and Illumination, permits the addition of a "fan" symbol to a control that is identified by the word "fan" in accordance with the requirements of S4.2.1.

The AMC interpretation is incorrect. Section S4.2.1 states in part:

S4.2.1 . . . . A control may, in addition, be identified by a symbol, but only a symbol shown in column 3 or 4 shall be used. However, if the word "None" appears in column 3, no symbol shall be provided. . . .

Table I, whose columns are referred to in S4.2.1, contains an entry for "Heating and Air Conditioning System," and column 3 for that entry contains the word "None". This means that no symbol can be used in addition to the word "fan" on the control for the fan control switch.

The language in the preambles to three proposals to amend Standard No. 101 that you list in your letter does not have the effect of amending the requirements of the standard itself. As you are no doubt aware, a recent proposal would amend Table I to include a symbol for the heating and air conditioning system, but this proposal has not yet been made final. A copy of the proposal is enclosed for your information.

SINCERELY,

American Motors Corporation

September 7, 1976

Robert L. Carter Associate Administrator Motor Vehicle Programs National Highway Traffic Safety Administration U. S. Department Of Transportation

American Motors Corporation (AM) submits this request for an interpretation of the control identification requirements contained in FMVSS 101 as they relate to the fan control switch of the heater and/or air conditioning system.

AM requests this interpretation because of the language contained in Docket 1-18; Notice 7, 10 and 11. Therein, the NHTSA has stated their tentative determination that a fan symbol should be allowed, at the manufacturer's option, to supplement the word "Fan" or "Blower" for purposes of identifying the fan control switch, and has announced its intention to incorporate the internationally accepted ISO fan symbol into Standard 101.

AM is about to release a future heater and air conditioner control assembly which will incorporate the word "Fan" along with the appropriate symbol described in ISO Standard 2575/1 (4.8). AM requests NHTSA's interpretation in order to assure that our incorporation of the ISO fan symbol will not be judged in conflict with the requirements of Standard 101.

A prompt reply to this request would be appreciated in order to facilitate this design decision.

K. W. Schang Director - Vehicle Safety Programs