Interpretation ID: aiam2962
Technical Assistant
Product Compliance
Subaru of America
Inc.
7040 Central Highway
Pennsuaken
NJ 08109;
Dear Mr. Cordner:#I regret the delay in responding to your letter o October 17, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls, (sic) and Displays*. You asked whether placing the turn signal symbol on the turn signal switch handle so that the arrows are vertical would comply with the standard.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear preceptually (sic) upright to the driver. The purpose of that requirement is to ensure quick and accurate identification of the vehicle controls. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle.#Sincerely, Frank Berndt, Acting Chief Counsel;