Interpretation ID: aiam3009
Vice President and General Manager
Engine Division
McCulloch Corporation
P.O. Box 92180
Los Angeles
j California 90009";
Dear Mr. Nodar: This is in reply to your letter of March 28, 1979, asking for a interpretation of Federal Motor Vehicle Safety Standard No. 123 as it relates to a manual fuel shut off control design that McCulloch Corporation wishes to incorporate in a future model.; Table 1 of Standard No. 123 specified the following operating position for a manual fuel shut off control: 'Off' - control forward, 'On' - control downward, and 'Reserve' (if provided) - control upward. The control that McCulloch would like to provide is a simple on-off knob control that in plan view is perpendicular to the ground and operates from on to off when a seated operator rotates it to the right, or counter-clockwise, direction. The control would be identified by the words 'Fuel off' and an arrow pointing to the right.; In our opinion, the McCulloch control does not comply with Standard No 123. The safety rationale for NHTSA's operating position is expressed in the response to petitions for reconsideration of the rulemaking action that adopted it:; >>>'The NHTSA has determined that the control should be standardized b requiring its operation along a longitudinal rather than a transverse axis. In this location there is a greater likelihood that in the event of a crash the control will be carried by inertia to the off position, thereby shutting off the fuel' (37 FR 17474, Aug. 29. 1972).<<<; The McCulloch control possesses neither the control positions no identification specified by Standard No. 123, nor does it appear that, in a crash, inertia would carry it to an off position.; Sincerely, Frank Berndt, Acting Chief Counsel