Interpretation ID: 1982-1.21
TYPE: INTERPRETATION-NHTSA
DATE: 03/05/82
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: BMW of North America, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter asking several questions about the use of informational readout displays in relation to FMVSS 101-80, Controls and Displays; 105, Hydraulic Brake Systems; and 208, Occupant Crash Protection.
Each of your questions assumes the use of informational readout displays as telltales. The light intensity requirements of Standard No. 101-80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.
The agency has recently issued a notice of proposed rulemaking (NPRM) that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.
I would like to point out the following statement in the NPRM:
Various amendments may be necessary to Standard No. 101-80, as well as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.
We would welcome any comments that you might have on this matter to assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.
The following discussion explains the effect that the proposal would have on your questions.
Question 1
Your first question asks whether the words "Fasten Seat Belts" may be used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208. The answer would be yes under the proposal. The NPRM states:
Sections S4.5.3.3(b) and S7.3 of @ 571.208 would be amended to permit the words "Fasten Belts" or "Fasten Seat Belts" as an alternative to the seat belt warning symbol in informational readout displays.
Question 2 Your second question concerns the possibility of allowing cancellation of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.
While the question is asked separately for the seat belt telltale and telltales not required by any safety standard in the first place, the answer is not dependent on that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated, that telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet the requirements that it not be variable and that it be visible to the driver under all daytime and nighttime conditions.
We note that the activation requirements for the seat belt telltale depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.
Section S4.5.3.3 requires a different type of warning system for automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.
Question 3
Your third question asks whether it is permissible to use an informational readout display to meet the visual brake warning system requirements of Standard No. 105. The answer would be yes under the proposal.
Section S5.3.5 of Standard No. 105 states:
Each indicator lamp shall have a lens labeled in letters not less than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red . . . .
It is our interpretation that the illuminated pattern of letters and glazing of an informational readout display would constitute a "lens labeled in letters." This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.
Question 4
Your fourth question asks whether an informational readout display specifying specific brake problems constitutes separate indicator lamps under the language of Standard No. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.
Section S3 of Standard No. 105 specifies various performance requirements for brake system indicator lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.
It is our interpretation that if a manufacturer separately meets the requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.
Question 5
Your fifth question asks about the requirements for an informational readout display which is a telltale. The NPRM proposes the following language:
S5.3.3.2 Telltales and gauges incorporated into informational readout displays --
(a) Shall have not less than two levels of light intensity, a higher one for day and a lower one for nighttime conditions.
(b) In the case of telltales and gauges not equipped with a variable light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.
(c) In the case of telltales and gauges equipped with a variable light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.
The agency does find the system that you are considering developing very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that you might be considering.
Sincerely,
ATTACH.
BMW OF NORTH AMERICA, INC.
March 19, 1981
Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration, U.S. Department of Transportation
RE: Request for Interpretation Informational Readout Displays
Dear Mr. Berndt
This letter seeks confirmation of interpretations we discussed with Mr. Carson in our meeting with him on December 18, 1980. The questions we have relate to the use of Informational Readout Displays under FMVSS 101, 208, 105.
To better understand our questions, we are enclosing a description of the display system to which our questions apply.
Question 1
This question relates to the use of the words "Fasten Seat Belts" in the case of an informational readout display.
FMVSS 101-80, S5.2.3 permits informational readout displays to use the word or abbreviation shown in Table 2, Column 3 instead of the seat belt warning symbol. Column 3, however, provides no word or abbreviation, but instead refers to FMVSS 208. FMVSS 208, S7.3. only permits the use of words before September 1, 1980.
We believe this was an oversight when identification requirements of FMVSS 101 and 208 were consolidated in 45FR47151. In 43FR27541, it is made clear that NHTSA intends to further the development of readout displays by permitting optional use of symbols or words.
We request comment on our interpretation that the words FASTEN BELTS or FASTEN SEAT BELTS can be used in a readout display instead of a symbol to comply with the visual seat belt-warning requirements of FMVSS 101-80 and 208.
Question 2
This question relates to the activation or deactivation of displays by a voluntary manual action by the driver (pressing a push button control).
a. FMVSS 208, S7.3 requires a visual seat belt warning system that, triggered by the ignition, activates from 4 to 8 seconds. If a multi-message informational readout display is used as the visual seat belt warning (as described in Question 1), would it be permitted to provide a push button that cancels the seat belt warning by a voluntary manual action of the driver in favor of a readout for a malfunction or other warning. Would the above be permitted if a symbol in the readout went on for the duration of the 4 to 8 seconds?
b. FMVSS 101 by itself does not require that the displays listed in Table 2 be provided.
Basically the same question as 2a. applies to the other displays listed in Table 2, for which no requirement for activation in a reference standard exists.
If a multi-message informational readout display is used for any of those displays, would it be permitted to provide a push button that cancels such displays by a voluntary manual action of the driver.
Question 3
This question relates to the use of light emitting diodes or light emitting crystals to display the word "BRAKE" as required by FMVSS 105.
FMVSS 105, S5.3.5 requires a visual brake warning system using an indicator lamp with a lens labeled in letters. Would it be permissible to use an informational readout display for this purpose, considering the illuminated pattern of letters and its glazing as a "lens labeled in letters?"
Question 4
This question relates to the display of clarifying words in addition to the display "BRAKE."
FMVSS 105, S5.3.5 permits the use of a single brake warning indicator lamp, but requires that if separate indicator lamps are used for the various functions of S5.3.1(a)-(d), then each indicator must be separately and appropriately labeled. However, FMVSS 101-80, S5.2.3 in addition to the required words of Table 2, Column 3, permits the use of clarifying words at the manufacturer's discretion. If a separate, single brake warning indicator lamp, which by itself fulfills the requirements of FMVSS 105, is supplemented by an informational readout specifying the particular brake problem, would the readout be considered clarifying words or separate indicator lamp? The importance of this question is that, in the event of function checking (S5.3.2) or multi-malfunction (S5.3.5), while the BRAKE warning light would illuminate, the readout display could only illuminate one message at a time relative to the S5.3.1(a)-(d) functions.
We request comment on our interpretation that the readout constitutes clarifying words rather than separate indicator lamps because the brake warning lamp separately fulfills the requirements of S5.3.5.
Question 5
This question relates to the light intensity of informational readout displays.
FMVSS 101 S5.3.3.b requires: ". . . light intensities for informational readout systems shall have at least two values . . ." and ". . . The light intensity of each telltale shall not be variable and shall be . . . . visible to the driver under all daytime and nighttime conditions."
What are the requirements for an informational readout display if it displays a message which, by definition of FMVSS 101, S4, qualifies as a telltale?
We would appreciate your giving these questions your earliest possible attention.
Very truly yours
Karl-Heinz Ziwica, Manager -- Safety & Emission Control Engineering
Enclosures
DESCRIPTION OF SYSTEM
Display fields above speedometer, immediately in front of driver.
(Graphics omitted)
Display I
This display uses light emitting diodes or light emitting crystals to display words.
It displays the word "BRAKE" whenever required by FMVSS 105. Specific brake information will simultaneously appear on Display II.
Display II
This display uses light emitting diodes or light emitting crystals to display words.
This information readout display (multi-message) informs the driver of malfunctions or provides warnings.
Messages displayed are some of those listed in FMVSS 101-80, Table 2:
- Fasten seat belts
- Fuel level
- Oil pressure
- Coolant temperature
- Electrical charge
and in addition terms such as
- Brake wear
- Headlamp or taillamp
- Fluid levels (engine oil, transmission oil, coolant, washer)
In the event of a multi-malfunction, a computer chooses the message to be displayed on the basis of priority. The symbol to the right of the message field informs the driver of the existence of a multi-malfunction.
Display III
A warning light (lens and bulb) calls for the driver's attention and informs him of the importance of the message by either a blinking (high priority) or steady illumination (low priority).
Selector Control
With this push button control the driver can manually activate or deactivate the message on Display II (multi-message display).
In the case of a double malfunction, the first malfunction is indicated; after pressing the push button, the display indicates the second malfunction.
Example of the sequence of displays which are illuminated in case of a double malfunction: (Graphics omitted)
DRIVER PRESSES THE SELECTOR CONTROL.
(Graphics omitted)