Interpretation ID: aiam3532
Manager
Safety and Emission Control engineering
BMW of North America
Inc.
Montvale
NJ 07645;
Dear Mr. Ziwica: This responds to your letter asking several questions about the use o informational readout displays in relation to FMVSS 101-80 *Controls and Displays*, 105 *Hydraulic Brake Systems* and 208 *Occupant Crash Protection*.; Each of your questions assumes the use of informational readou displays as telltales. The light intensity requirements of Standard No. 101- 80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; The agency has recently issued a notice of proposed rulemaking (NPRM that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.; I would like to point out the following statement in the NPRM: >>>Various amendments may be necessary to Standard No. 101-80, as wel as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.<<<; We would welcome any comments that you might have on this matter t assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.; The following discussion explains the effect that the proposal woul have on your questions.; *Question 1* Your first question asks whether the words 'Fasten Seat Belts' may b used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208.the answer would be yes under the proposal. The NPRM states:; >>>Sections S4.5.3.3(b) and S7.3 of S571.208 would be amended to permi the words 'Fasten Belts' or Fasten Seat Belts' as an alternative to the seat belt warning symbol in informational readout displays.<<<; *Question 2* Your second question concerns the possibility of allowing cancellatio of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.; While the question is asked separately for the seat belt telltale an telltales not required by any safety standard in the first place, the answer is not dependent of that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated the telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet requirements that it not be variable and that it be visible to the drive under all daytime and nighttime conditions.; We note that the activation requirements for the seat belt telltal depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.; Section S4.5.3.3 requires a different type of warning system fo automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.; *Question 3* Your third question asks whether it is permissible to use a information readout display to meet the visual brake warning system requirements of Standard NO. 105. The answer would be yes under the proposal.; Section S5.3.5 of Standard No. 105 states: >>>Each indicator lamp shall have a lens labeled in letters not les than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red....<<<; It is our interpretation that the illuminated pattern of letters an glazing of an information readout display would constitute a 'lens labeled in letters.' This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.; *Question 4* Your fourth question asks whether an informational readout displa specifying specific brake problems constitutes separate indicator lamps under the language of Standard NO. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.; Section S3 of Standard No. 105 specifies various performanc requirements for brake system indicators lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.; It is our interpretation that if a manufacturer separately meets th requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.; *Question 5* Your fifth question asks about the requirements for an informationa readout display which is a telltale. The NPRM proposes the following language:; >>>S5.3.3.2 Telltales and gauges incorporated into informationa readout display--<<<; >>>(a) Shall have not less than two levels of light intensity, a highe one for day and a lower one for nighttime conditions.<<<; >>>(b) In the case of telltales and gauges not equipped with a variabl light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.<<<; >>>(c) In the case of telltales and gauges equipped with a variabl light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.<<<; The agency does find the system that you are considering developin very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that your might be considering.; Sincerely, Frank Berndt, Chief Counsel