nht87-2.93 | NHTSA

TYPE: INTERPRETATION-NHTSA

DATE: 09/14/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: K. Shimamura -- (Shiramura) -- Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mazda (North America), Inc. Research & Development Center 1203 Woodbridge Avenue Ann Arbor, Michigan 48105

Dear Mr. Shiramura: This responds to your letter requesting an interpretation of Standard No. 101, Controls and Displays. You described a proposed integrated steering column/dashboard display and asked whether controls mounted on such a unit must be illuminated. As discusse d below, the answer to your question is no.

By war 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 manufac turing to ensure that its motor vehicles or equipment comply with applicable safety standard. The following represent our opinion based on the facts provided in your letter.

Section 55.3.1 of Standard No. 101 states that "(e)xcept for foot-operated control; or hand-operated controls mounted upon the floor, floor console, or steering column, or in the windshield area, the identification required by 55.2.1 or 55.2.2 of any con trol . . . shall be illuminated . . . ."

The primary issue raises by your letter is whether the controls mounted on your proposed steering column/dashboard display come within section @5.3.1's exception for controls mounted upon the steering column and therefore need not be illuminated. You des cribed your proposed design as follows:

". . . In addition to the usual plastic trim molding that currently encloses the steering column between the instrument panel and the actual steering wheel, the new design adds an integrated upper section accommodating the vehicle's gauges and displays ( such as speedometer and tachometer). The upper section is completely integrated into the lower, usual column trim molding and the unit is a single molded part.

A drawing enclosed with a subsequent letter indicates that the upper section described above is mounted by brackets onto the energy absorbing shaft, below the steering wheel and above the pivot used to adjust the steering wheel.

Thus, as the steering wheel is adjusted, the upper section is also adjusted, maintaining the same relative position to the steering wheel.

You suggest that the proposed integrated unit can be considered to be a "steering column," citing the definition of that term used in Standard No. 204. We note that Standard No. 204's definition of steering column' does not apply to Standard No. 101. Mor eover, the upper section itself need not be considered a steering column in order to come within Standard No. 101's exception. In a Federal Register notice published on May 4, 1971, NHTSA stated the following about similar language in an earlier version of Standard No. 10".

Ford has asked whether steering-wheel mounted controls are exempt from illumination requirements. Since the steering wheel itself is mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls ext ends to those mounted on the steering wheel as well. 36 ER 8297, May 4, 1971. Since the upper section in your proposed design is, at the least, mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls extends to those mounted on the upper section as well. Therefore, cont rols mounted on the upper section need not be illuminated. We note that it is unnecessary for us to reach a determination of whether the upper section can be considered to be a steering column for purposes of Standard No. 101.

Sincerely,

Erika Z. Jones Chief Counsel

April 8, 1987

Ms. Erika Z. Jones Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street. S.W. Washington, D.C. 20550

Re: Request for Interpretation-Part 571, Federal Motor Vehicle Safety Standards, Sections 571.100 and 571.101; Controls and Displays Dear Ms. Jones:

Mazda (North America), Inc. and its parent company, Mazda Motor Corporation ("Mazda"), request that the National Highway Traffic Safety Administration consider an interpretive question relating to the above captioned Safety Standard. Although Mazda is aw are that the agency is not authorized to pass on the conformity of and specific product design prior to introduction of that product into the marketplace. the comments of you and your staff have in the past been extremely helpful in better understanding the requirements of the various safety Standards. It is this assistance that is again requested.

The question Mazda submits relates to the provisions of FMVSS 100/101, S5.3.1. Illumination. This section states, "(except for foot-operated controls or hand-operated controls mounted upon the floor. Floor console, or steering column, or in the windshiel d area, the identification required by 55.2.1 or @5.2.2. or any control...shall be illuminated..."

Mazda has conceived a proposed steering column design that incorporates several unique features. In addition to the usual plastic trim molding that currently encloses the steering column between the instrument panel and the actual steering wheel, the new design adds an integrated upper section accommodating the vehicle's gauges and displays (such as speedometer and tachometer). The upper section is completely integrated into the lower, usual column trim molding and the unit is a single molded part.

Several controls are to be placed on the upper section. The turn signal and automatic speed control are to be mounted on the front face. The master lighting switch and wiping system controls will be positioned on either side of the upper section. The haz ard warning control will be at the base of the upper section and on top of the lower column trim panel. These controls will not be illuminated. 49 CFR Part 571.204, Steering Control Reward Displacement explains in @1. that a "steering column" is a "struc tural housing that surrounds a steering shaft (a component that transmits steering torque from the steering wheel to the steering gear.) Mazda's question, therefore is twofold. Does the proposed integrated steering column/dashboard display constitute a s teering column and, based on the answer to the first question, must controls mounted on this unit be illuminated?

We have considered this question internally and have tentatively concluded that the proposed integrated unit can be defined as a steering column applying the criteria of FMVSS 204. To our knowledge, FMVSS 204 provide; the only official definition of stee ring column provided through the public record. Insofar as this term is specified in FMVSS 100/101. it would seen reasonable to apply this definition. By so doing, it is apparent that the integrated steering column molding is a "structural" housing in th at it provides for the location,

June 17, 1987

Mr. Edward Glancy Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, DC. 20590

Re: Supplemental Information - Request for Interpretation Regarding FMVSS 100/101, Controls and Displays

Dear Mr. Glancy:

Please find attached a rendering of Mazda's new steering column design which is the subject our April 8, 1987 request for interpretation. The illustration depicts the relevant assemblies and corresponding mounting locations that you indicated would be he lpful in your deliberations.

We trust this information will be useful. However; if you should have any other further questions related to the structure and configuration of our new system or on any other topic applicable to this question, please do not hesitate to contact me at this letterhead or telephone the number above.

Thank you for your assistance in this matter.

Sincerely,

Steve L. Underwood Assistant Manager Safety Engineering

Interpretation ID: nht87-2.93