Interpretation ID: 2701y
Human Factors Engineer
Arcad
l2025 Tech Center Dr.
Livonia, MI 48l50
Dear Mr. Donaldson:
This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. l0l, Controls and Displays. I apologize for the delay in our response. You asked about the requirements of sections S5.l and S5.3.3(a) in connection with an instrument panel illumination intensity control. Your question is addressed 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 and equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.
As noted by your letter, section S5.l of Standard No. l0l reads as follows:
S5.l Location. Under the conditions of S6, each of the following controls that is furnished shall be operable by the driver, and each of the following displays that is furnished shall be visible to the driver. . . .
One of the controls listed under section S5.l is a hand-operated control for illumination intensity. Thus, under section S5.l, an instrument panel illumination intensity control is required to be in a location where it is operable by the driver.
You also noted that section S5.3.3(a) requires that "(m)earns shall be provided for making controls, gauges, and the identification of those items visible to the driver under all driving conditions." You asked whether, under this section, an instrument panel illumination intensity control is required to be "visible to the driver." As discussed below, section S5.3.3(a) does not apply to an instrument panel illumination intensity control.
Section S5.3.3(a) is one of a number of sections which appear under the heading "Illumination." See section S5.3. Standard No. l0l does not require that all controls be illuminated. Section S5.3.l sets forth requirements concerning which controls must be illuminated. Section S5.3.3(a) then sets forth additional illumination requirements for the controls which must be illuminated and their identification (as well as for gauges and their identification).
In order to determine whether section S5.3.3(a) applies to a particular control, the first question is thus whether Standard No. l0l requires illumination for that control. As indicated above, this is covered in section S5.3.l. It provides that, with certain exceptions, the identification required by S5.2.l or S5.2.2 for any control listed in column l of Table l and accompanied by the word "yes" in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. (Column 4 of Table l includes the heading "Illumination.") Thus, Standard No. l0l requires illumination only for those controls which are listed in Table l and have the word "yes" in the column for illumination.
Since an instrument panel illumination intensity control is not listed at all in Table l, no illumination is required by Standard No. l0l for that control. Given that section S5.3.3(a)'s additional illumination requirements only apply to controls which Standard No. l0l requires to be illuminated, and since no illumination is required for an instrument panel illumination intensity control, the section's requirements do not apply to that control.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:l0l d:l0/l7/90