Interpretation ID: aiam2923
Sr.
Director of Engineering
R. E. Dietz Company
225 Wilkinson Street
Box 1214
Syracuse
NY 13201;
Dear Mr. Vescio:#This responds to your letter of September 21, 1978 requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.#In your first set of questions, you ask about the application of the display requirements to trucks with GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.#In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is 'no.' S5.2.1 provides that the symbol shall be placed on *or* adjacent to the control. You also ask if there is any size requirement. The answer is again 'no.' There are no size requirements for any of the control symbols.#In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand-operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the non-mandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.#In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;