Interpretation ID: 8745
Manager, Product Safety & Compliance
Kenworth Truck Company
P. O. Box 1000
Kirkland, WA 98083-1000
Dear Mr. Degenstein:
This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked whether a control for an automatic vehicle speed system (also known as a cruise control) would meet the location requirement of Standard No. 101, and whether the control must be illuminated. As explained below, the answer to both questions is yes.
Your letter explained that your company is developing a vehicle that "will locate a cruise control switch in a console that is attached to the manual transmission shift lever, adjacent to the shift knob." You state that the switches on the console will be "operable by the driver." You believe that because the cruise control console's location is similar to that of a switch located on the vehicle floor console, illumination of the cruise control is not necessary.
Your first question asks whether the proposed location of the cruise control would meet Standard No. 101. S5.1 of Standard No. 101 specifies that each control listed in S5.1 "that is furnished" must be operable by the driver. S5.1 lists, under the heading of "hand operated control," the automatic vehicle speed system (i.e., the cruise control). Thus, under S5.1, a furnished hand operated cruise control must be operable by the driver.
It appears from your letter that the switches on the cruise control console are operable by the driver. Two photographs you enclosed show the cruise control as mounted on the manual transmission shift lever, and as located so close to the driver's seat as to be almost touching it. Accordingly, the proposed location of the cruise control console would be permitted by Standard No. 101.
Your second question asks whether your proposed cruise control would be subject to the illumination requirements of S5.3 of
Standard No. 101. S5.3.1 sets requirements concerning controls which must be illuminated. It provides that (except for hand operated controls mounted on the floor), any control listed in column 1 of Table 1 and accompanied by the word "yes" in column 4, "Illumination," shall be capable of being illuminated whenever the headlights are activated. The automatic vehicle speed control is listed in column 1 of Table 1 and is accompanied by "yes" in column 4. Therefore, Standard No. 101 specifies that the cruise control must be capable of being illuminated whenever the headlights are activated, unless it is otherwise excepted in S5.3.1. As explained below, your cruise control would not be excepted.
You believe that the control is akin to being "mounted on the floor console" and thus excluded from S5.3.1's illumination requirements. We disagree. The dictionary definitions of "mount" include "to place on something raised," and "to place, fix, or fasten on or in the proper support, backing, etc. for the required purpose." (See Webster's New World Dictionary, College Edition.) Both definitions support the view that the cruise control console is "mounted" on the transmission shift lever, not the floor. The console is placed on the transmission shift lever (i.e., "something raised"), and is "place(d), fix(ed) or fasten(ed)" on the transmission shift lever for the "required purpose" of being operable by hand. The console with the cruise control would not be operable by hand if the console were "mounted" on the floor. Since the cruise control console is mounted on the manual transmission shift lever, not on the floor, it is not excluded by S5.3.1 from the illumination requirements.
I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.
Sincerely,
John Womack Acting Chief Counsel
ref:101 d:9/7/93