Interpretation ID: aiam1969
Director/General Manager
Toyota Motor Sales
U.S.A.
inc.
1099 Wall Street
West Lyndhurst
New Jersey 07071;
Dear Mr. Nakajima: This responds to Toyota's June 9, 1975, request for confirmation tha S5.3.2 of Standard No. 105-75, *Hydraulic brake system*, requires a check of the brake system indicator lamp function only when the transmission is in the 'P' (park) position or the 'N' (neutral) position.S5.3.2 specifies:; >>>S5.3.2 All Indicator lamps shall be activated as a check of lam function either when the ignition (start) switch is turned to the 'on' ('run') position when the engine is not running, or when the ignition (start) switch is in a position between 'on' ('run') and 'start' that is designated by the manufacturer as a check position.<<<; The wording of S5.3.2 requires a check of lamp function without regar to the position of the transmission shift lever whenever the ignition switch is in one of the positions described. In the case of vehicles equipped with automatic transmission, this language does not reflect the National highway Traffic Safety Administration's (NHTSA) intent that the check function occur during the process of starting the vehicle.; To incorporate the intended meaning of the requirement into th standard, the NHTSA will shortly issue an interpretative rule that modifies the language of s%.3.2 by limiting the check function to the park an neutral positions for vehicles with automatic transmission.; Sincerely, James D. Schultz, Chief Counsel