Interpretation ID: aiam3851
Senior Safety Engineer
Grumman Olson
70180 Centerville Road
Sturgis
MI 49091;
Dear Mr. White: This responds to your letter of May 3, 1984, asking about Standard No 101, *Controls and Displays*. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listed in that table. You asked whether the symbols are required to be illuminated or whether it is permissible instead to illuminate the identifying words without illuminating the symbols. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.; By way of background information, I would note that the Nationa Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.; Section S5.2.1 of Standard No. 101 generally requires that 'an hand-operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol.' The section states further that '(s)uch a control may, in addition, be identified by the word heating fan, windshield wiper and washer, and defroster system, all are listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.; Section S5.3.1 of Standard No. 101 states: >>>Except for foot-operated controls or hand-operated controls mounte upon the floor, floor console, or steering column, or in the windshield header area, the *identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield....(Emphasis added.)<<<; As discussed above, the identification required by section S5.2.1 fo the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word 'yes' in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated. It is thus not permissible to illuminate the identifying words without also illuminating the symbols.; I would note that your letter does not provide sufficient informatio to determine whether the controls in your proposed design could come within any of Standard No. 101's exceptions to the illumination requirements.; Sincerely, Frank Berndt, Chief Counsel