Interpretation ID: aiam3142
Manager
Vehicle Products Group
Veeder-Root Company
Hartford
Connecticut 06102;
Dear Mr. Sinder: This is in response to your letter of August 21, 1979, asking whethe Federal Motor Vehicle Safety Standard No. 127, *Speedometers and Odometers*, applies to your product, the Veeder-Root 7-Day Tachograph, and whether the odometer provisions of the standard would apply if your product were installed in vehicles with gross vehicle weight ratings (GVWR) of less than 16,000 pounds. You also asked whether a tachograph installed in a school bus as a replacement for the speedometer and marked with speeds from 0 to 50 mph on both the dial and on the inside chart would comply with Safety Standard 127.; Section 4.1.1 of Safety Standard 127 requires that 'each motor vehicl shall have a speedometer that meets the requirements ...' of the standard. Section 4.2.1 requires that 'each motor vehicle with a gross vehicle weight rating of 16,000 pounds or less shall have an odometer that meets the requirements ...' of the standard. Therefore a tachograph installed in lieu of the speedometer and odometer in a new vehicle with a gross vehicle weight rating of 16,000 pounds or less must meet both the speedometer and the odometer requirements of Safety Standard 127. If the new vehicle in which the tachograph were installed had a gross vehicle weight rating greater than 16,000 pounds the speedometer requirement of Safety Standard 127 would apply but the odometer requirements would not.; If the tachograph were installed in a new vehicle as a supplement to existing speedometer and odometer which meet the requirements of Safety Standard 127, the provisions of Safety Standard No. 127 would not apply to the tachograph.; Section 4.1.4 of Safety Standard 127 provides that: >>>No speedometer shall have graduation or numerical values for speed greater than 140 km/h and 85 mph and shall not otherwise indicate such speeds.<<<; Although this section specifies the maximum speed indication which ma appear on the dial of a speedometer, it does not prohibit the use of a lower maximum speed indication. Section 4.1.5 of the standard provides that 'each speedometer shall include the numeral '55' in the mph scale.' However, this provision assumes that the speedometer dial will have calibrations for speeds in excess of 55 mph. If the speedometer dial will not include calibrations for speeds of 55 mph and above, then there is no requirement that the numeral 55 be included in the mph scale. This follows from the rationale on which Safety Standard 127 is based, which is to reduce the temptation for drivers to test the top speeds of their vehicles and to induce greater compliance with the national maximum speed limit of 55 mph.; I hope that you will find this response helpful and have not bee greatly inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel