Interpretation ID: aiam2901
Manager
Regulatory Affairs
Product Planning and Development
Volvo of America Corporation
Rockleigh
NJ 07647;
Dear Mr. Shapiro:#This is in response to your letter of September 20 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.#Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.#Section 5.2.3 of the standard provides that 'any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3.' There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;