Interpretation ID: aiam2932
Mercedes-Benz
P.O. Box 350
Montvale
NJ 07645;
Dear Mr. Gerth:#This is in response to your letter of November 27 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. Specifically, you asked whether it is permissible to use symbols for the parking lamp functions of the headlamp switch, in addition to the headlamp symbols required in Table I of the Standard.#The answer to your question is yes. Section 5 of the standard states that each passenger car 'with any control listed in S5.1 or in column 1 of Table 1, ... shall meet the requirements of this standard for the location, identification, and illumination of such control or display.' Since no symbols or other designations are required under the standard for parking lamps where their control is not combined with that for headlamps or for 'lamps-off' positions on controls, it is up to the manufacturer whether to label these additional functions and whether to use words or symbols. Footnote 2 of Table 1 of the standard does provide that a manufacturer must use the single headlamp symbol to designate several functions when clearance, identification, parking and/or side marker lamps are all controlled with the headlamp switch. This footnote was not intended to preclude additional symbols for these other functions, however. In fact, S5.2.1 provides that 'additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity.'#Regarding your drawings, clearance lamps are listed in paragraph S5.1 and in column 1 of Table 1 of the standard. Therefore, they must be identified by the symbols shown in column 3 of Table 1 or by the words 'Clearance Lamps' or 'Cl Lps'. The 'parking right and left' symbol shown on the drawing submitted with your letter would not satisfy the requirements for clearance-lamp designations. However, the symbol labeled 'Clearance Lamps' that appears on the drawings which Mr. Gebhard M. Hespeler and Mr. Craig Jones submitted on December 20, 1978, would conform with the requirements. I have enclosed a copy of that drawing.#If you have any further questions, please do not hesitate to write.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;