Interpretation ID: aiam4041
Executive Vice-President and General Manager
Mazda (North America)
Inc.
Detroit Office
24402 Sinacola Court
Farmington Hills
Michigan 48018;
Dear Mr. Moriyoshi: This responds to your letter requesting an interpretation of Federa Motor Vehicle Safety Standards No. 101, *Controls and Displays*, and NO. 102, *Transmissions Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect*. You asked about the identification and visibility requirements of these standards for the gear position indicator of an automatic transmission. As part of a design you are considering producing, a gear position indicator, using light- emitting diodes (LED's), would be located within the instrument panel. Your letter states that this system would conform with all applicable requirements when the ignition switch is in the on and start positions, but would not be visible when the ignition switch was in the accessory or off positions. Your letter states further that, in addition to this LED display, the steering- column-mounted gear shift selector would be provided with embossed position indicators conforming to Standard No. 102, except that the identifiers would only be visible from the inboard side of the steering column and thereby require the driver to lean forward and to the right for visual confirmation of the automatic gear position. The issues raised by your letter with respect to whether the design you are considering would comply with Standard No. 101 and No. 102 are addressed below.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide approvals of motor vehicle or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. the following represents our opinion based on the facts provided in your letter.; I will begin by identifying the requirements of Standards No. 101 an No. 102 that are relevant to your request. Section S3.2 of Standard No. 102 states that the '(i)dentification of shift lever positions of automatic transmissions and of the shift lever pattern of manual transmissions . . . shall be *permanently displayed in view of the driver*.' (Emphasis added.); Standard No. 101 specifies requirements for the location identification and illumination of automatic gear position displays. Section S5.1 requires that gear position displays must be visible to the driver under the conditions of section S6. Section S6 provides that the driver is restrained by the crash protection equipment installed in accordance with Standard No. 208, *Occupant Crash Protection*, adjusted in accordance with the manufacturer's instructions. Section S5.3.1 and Table 2 of the standard together require that automatic gear position displays be illuminated whenever the ignition switch and/or the headlamps are activated. The entry in Table 2 concerning the automatic gear position display reference Standard No. 102.; I will now address these requirements in relation to the design you ar considering. As discussed below, it is our opinion that your proposed design would not meet Standard No. 102's requirement that the identification of shift lever positions of automatic transmissions must be permanently displayed in view of the driver.; While your design would include two automatic gear position displays *neither* display would provide identification of shift lever positions of automatic transmissions in view of the driver when the ignition switch is in the accessory or off position. As noted by your letter, NHTSA has interpreted the words 'permanently displayed' to require a display which can be seen regardless of the operating mode of the engine. The display on the instrument panel would not be visible when the ignition switch is in the accessory or off positions. The other display, located on the steering column, would not be visible to the driver regardless of the position of the ignition switch.; NHTSA has previously addressed Standard No. 102's requirement tha certain identification be 'in view of the driver' in connection with a request for interpretation concerning the identification of the shift lever pattern of manual transmissions. The agency concluded that the pattern 'is deemed to be 'displayed in view of the driver' if part of it may be seen from the driver's normal eye position and a reasonable amount of movement of the driver allows him to gain full view of the pattern.' (Letter to Daimler-Benz of North America, February 27, 1967); As noted above, your letter states that the display on the steerin column would 'only be visible from the side of the steering column and thereby require the driver to lean forward and to the right for visual confirmation of the automatic gear position.' This suggests that little, if any, of the display may be seen from the driver's normal eye position and that a significant amount of movement of the driver would be required to see the full display. This is further confirmed by a statement in your letter indicating that the driver would need to lean forward, utilizing the flexibility provided by an emergency locking retractor, in order to see the display, and then *return* to the normal driving position. (Emphasis added) It therefore appears that the display is not 'in view of the driver.'; While your letter suggest that the degree of visibility provided by th display might be appropriate for situations where the vehicle is not activated, Standard No. 102's requirement that the display be within the ' view of the driver' does not distinguish between whether the engine is on or off. We also note that a driver used to viewing the gear position indicator on the instrument panel might not be aware that another display, which would not be visible from a normal driving position, even exists.; Since neither display would provide identification of shift leve positions of automatic transmissions in view of the driver when the ignition switch is in the accessory or off position, it is unnecessary to address the issue raised by your letter concerning whether multiple and complementary indicator can be used to meet the requirements of Standards No. 101 and No. 102 for gear position displays, where no single indicator meets the requirements.; Sincerely, Erika Z. Jones, Chief Counsel