Interpretation ID: 86-3.30

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Karl-Heinz Faber, Vice President

TITLE: FMVSS INTERPRETATION

TEXT:

Karl-Heinz Faber, Vice President Product Compliance and Service Mercedes-Benz of North America, Inc. One Mercedes Drive, P.O. BoX 350 Montvale, NJ 07645

Dear Mr. Faber:

This responds to your letter addressed to Mr. Barry Felrice concerning Federal Motor Vehicle Safety Standard No. 101, Controls and Displays, and use of the "fanfare" symbol. According to your letter, all Mercedes-Benz passenger cars are provided with a horn that when activated produces an audible tone. The control for so activating the horn is located in the steering wheel hub. In addition to the standard horn, your company also offers an optional system on some models which permits the driver to choose either the standard tone or a higher frequency tone by means of a dash-board-mounted rocker switch. The rocker switch is identified by the fanfare symbol. The audible tone selected is then produced by activating the horn control in the steering wheel in the usual manner. This letter confirms that the use of the fanfare symbol for the rocker switch described above is permissible under Standard No. 101.

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 meet applicable safety standards. The following represents our opinion based on the facts provided in your letter.

Standard No. 101 requires that vehicles with any control listed in the standard must meet specified requirements for the location, identification and illumination of such control. See section S5. Among the controls listed in Standard No. 101 is the 'horn' control. See section S5.1 and column 1 of Table 1.

It is our opinion that the "horn" control referred to by Standard No. 101 is limited to that which activates the horn to produce an audible tone. Thus, a separate rocker switch which permits the driver to choose different tones but does not activate the horn to produce an audible tone is not considered to be a "horn" control within the meaning of Standard No. 101. Since a control of this type is not otherwise covered by Standard No. 101 or any other standard, the identification of the control is at the option of the manufacturer.

Sincerely,

Erika Z. Jones Chief Counsel