Interpretation ID: aiam3932
Manager
Certification Business Division
Mazda Motor Corporation
P. O. Box 18
Hiroshima
730- 91
Japan;
Dear Mr. Hayashibara: This responds to your letter concerning Federal Motor Vehicle Safet Standard No. 101, *Controls and Displays*. According to your letter, you are considering a bulb check system for telltales that operates while the ignition switch is turned to the 'on' position and the engine is not running. You stated that the proposed design of this system is such that all telltales subjected to the bulb check may emit light simultaneously when any malfunction occurs in the electrical charging system. You asked whether the proposed system would comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; Section S5.3.1 of Standard No. 101 states: >>>A telltale shall not emit light except when identifying th malfunction or vehicle condition for whose indication it is designed or during a bulb check upon vehicles starting.<<<; There are thus only two situations in which it is permissible for telltale to emit light: (1) when the telltale is actually identifying the malfunction or vehicle condition for which it is designed, and (2) during a bulb check upon vehicle starting. The emitting of light by all telltales whenever a malfunction occurs in the electrical charging system does not fall within either of these catagories and is therefore not permitted by the standard.; This interpretation is limited to the specific factual situatio described above, i.e., where light would be emitted by all telltales whenever a malfunction occurs in the electrical charging system. In essence, your proposed design would replace the telltale for electrical charge, which is provided by most manufacturers to warn of such things as low voltage, with a warning message in the form of all telltales simultaneously emitting a light. This is not permitted by Standard No. 101, for the reasons stated above.; Your letter suggests an interpretation that the simultaneous lightin of all telltales subjected to the bulb check when any malfunction occurs in the electrical charging system could not be any violation of the requirements of S5.3.1, because it is the vehicle condition which 'is designed' by a manufacturer for all telltales to emit light. We do not agree with that suggested interpretation. Section S5.3.1's use of the words 'malfunction of vehicle condition for whose indication it is designed' refers back to the term '(a) telltale.' It is our opinion that the phrase is applicable only to the specific malfunction or vehicle condition for which a particular telltale is designed to warn the driver and not to a situation where all telltales are designed to collectively warn of a malfunction or vehicle condition.; Our interpretation is not dependent on whether a vehicle is equippe with a telltale for electrical charge or not.; Sincerely, Jeffrey R. Miller, Chief Counsel