Interpretation ID: aiam4382
Executive Vice President and General Manager
Mazda (North America)
Inc.
Research & Development Center 1203 Woodbridge Avenue
Ann Arbor
MI 48105;
Dear Mr. Shimamura: This responds to your letter requesting an interpretation of Standar No. 101, *Controls and Displays*. You described a proposed integrated steering column/dashboard display and asked whether controls mounted on such a unit must be illuminated. As discussed below, the answer to your question is no.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment 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 that '(e)xcept fo foot-operated controls or hand-operated controls mounted upon the floor, floor console, or steering column, or in the windshield area, the identification required by S5.2.1 or S5.2.2 of any control . . . shall be illuminated . . . .'; The primary issue raised by your letter is whether the controls mounte on your proposed steering column/dashboard display come within section S5.3.1's exception for controls mounted upon the steering column and therefore need not be illuminated. You described your proposed design as follows:; >>>'. . . In addition to the usual plastic trim molding that currentl enclosed the steering column between the instrument panel and the actual steering wheel, the new design adds an integrated upper section accommodating the vehicle's gauges and displays (such as speedometer and tachometer). The upper section is completely integrated into the lower, usual column trim molding and the unit is a single molded part.; 'Several controls are to be placed on the upper section. The tur signal and automatic speed control are to be mounted on the front face. The master lighting switch and wiping system controls will be positioned on either side of the upper section. The hazard warning control will be at the base on the upper section and on top of the lower column. . . .'<<<; A drawing enclosed with a subsequent letter indicates that the uppe section described above is mounted by brackets onto the energy absorbing shaft, below the steering wheel and above the pivot used to adjust the steering wheel. Thus, as the steering wheel is adjusted, the upper section is also adjusted, maintaining the same relative position to the steering wheel.; You suggest that the proposed integrated unit can be considered to be 'steering column,' citing the definition of that term used in Standard No. 204. We note that Standard No. 204's definition of 'steering column' does not apply to Standard No. 101. Moreover, the upper section itself need not be considered a steering column in order to come within Standard No. 101's exception. IN a Federal Register notice published on May 4, 1971, NHTSA stated the following about similar language in an earlier version of Standard No. 101:; >>>Ford has asked whether steering-wheel- mounted controls are exemp from illumination requirements. Since the steering wheel itself is mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls extends to those mounted on the steering wheel as well. 36 FR 8297, Mary 4, 1971.<<<; Since the upper section in your proposed design is, at the least mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls extends to those mounted on the upper section as well. Therefore, controls mounted on the upper section need not be illuminated. We note that it is unnecessary for us to reach a determination of whether the upper section can be considered to be a steering column for purposes of Standard No. 101.; Sincerely, Erika Z. Jones, Chief Counsel