Interpretation ID: nht71-1.1
DATE: 05/19/71
FROM: AUTHOR UNAVAILABLE; R. L. carter; NHTSA
TO: SAAB-Scania of America, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your petition of March 12, 1971, for amendment of Motor Vehicle Safety Standard No. 101, Control Location, Identification, and Illustration.
You petitioned that the abbreviation for the defroster control identification be changed from "DEF" to "DEFR." In the preamble to the reconsideration and amendment of Standard No. 101, (36 F.R. 8269, May 4, 1971), a copy of which I enclose, this agency noted that additional identifying words or symbols are permissible if they do not conflict with the required or permissible words and symbols set out in Standard No. 101. In our opinion your use of "DEFR" would create no conflict.
You also petitioned that certain controls located below the drivers E point and available to all passengers be exempted from the control identification illumination requirement. The recent amendment to Standard No. 101 no longer requires illumination of all heating and air conditioning controls, but only those that direct air directly upon the windshield. We believe this may be responsive to your petition.
Finally, you asked that we define our position on bilingual control identification. Identification in a language other than English is permissible, in the
language of the preamble to the recent amendment, "as long as the additional words . . . do not conflict with the required words . . ."
We hope this answers your questions.
Sincerely,
ATTACH.
March 12, 1971
Docket Room National Highway Traffic Safety Administration
Our Reference: T. Needell
Reference: Petition for Rulemaking to Amend Federal Motor Vehicle Safety Standard 101 "Control Location, Identification and Illumination" Effective January 1, 1972 and September 1, 1972.
Gentlemen: Under the provision of Sub-part 553.31 of Sections 103 and 119 of The National Traffic and Motor Vehicle Safety Act of 1966, SAAB-Scania of America, Incorporated hereby petition that Federal Motor Vehicle Safety Standard 101 be amended as outlined below for the reasons included herein.
I - Table 1 "Control Identification and Illumination" list the acceptable abbreviation for a windshield wiping system control as "WIPE". Table 1 list the acceptable abbreviation for a windshield washing system control as "WASH". Both of these abbreviations contain 4 letters. However, Table 1 list the allowable abbreviation for a windshield defrosting system control as "DEF". (3 letters).
It is our opinion that some form of consistency is in order within Table I. Accordingly, we petition to change Column 2 of Table 1 to read so that the abbreviation "DEFR" (4 letters) is noted as an acceptable abbreviation for a windshield defrosting system control.
We believe that this abbreviation is completely concise as to its meaning. This Company has for several years used the abbreviation "DEFR" to identify the windshield defrosting controls of its products. To change the tooling necessary to bring this particular control into conformity with Column 2 of Table I would cause this Company to charge the customer an additional sum in excess of the list price of the vehicle. This, we feel, considering the above circumstances, is unfair to the purchaser.
II - Table I "Control Identification and Illumination" requires that all windshield Defrosting and Defogging Systems and heating and air conditioning controls be permissibly identified and illuminated. Table I makes no provision for the exclusion of rear passenger controls from this requirement.
This Company manufactures a vehicle offering sophisticated rear passenger-oriented controls, which are console mounted at the right side of the driver in approximate alignment with and just below the seated driver's 'H' point. These controls were primarily designed with the comfort of the rear passenger in mind and were so located to be accessible to any passenger in the vehicle.
Since these controls were so located, they, of course, are readily accessible to the driver, as well as rear passengers. SAAB has purposely located these controls to be placed so that the driver is capable of operating such without disturbing his vision. We feel the illumination of such controls will unnecessarily and dangerously burden the driver, by subconsciously attracting his vision to their location, while he performs relative adjustment.
Accordingly, we strongly appeal for amendment of Table I to so read that such rear passenger-oriented controls are not subject to the requirements of F.M.V.S.S. 101.
III - Nowhere, in the recent amendment to F.M.V.S.S. 101, do we note where it is unacceptable for control identification to appear in a bilingual (combination English/non-English) form. Although it is quite apparent which abbreviations or words or combination of abbreviations or words and symbols are permissible, nowhere can we find where bilingual identification is non-permissible.
Because the Administration's position on this subject is not defined within F.M.V.S.S. 101, many manufacturers may retool existing controls to bilingually conform to the requirements of this Standard. If in the event a manufacturer did bilingually retool his controls, it would be an extreme hardship on a smaller manufacturer if the Administration were to amend F.M.V.S.S. 101 so not to allow bilingual compliance in the future.
Accordingly, we ask that the Administration clearly define its position on bilingual identification in the content of F.M.V.S.S. 101. In so asking, we strongly urge that the Administration allow the use of bilingual controls for compliance with F.M.V.S.S. 101. The reasoning behind this request is evident. Immense financial burden will confront the small manufacturer forced to tool two individual sets of controls for the English and non-English speaking markets.
We ask that the Administration give this petition for rulemaking to amend Federal Motor Vehicle Safety Standard 101 very careful consideration. In view of the urgency involving the tooling now in progress for model year 1972, we feel that all you can do to expedite such amendment will be beneficial to the manufacturer.
Very truly yours,
SAAB-SCANIA OF AMERICA, INC.
Donald W. Taylor Product Technique Section Manager
cc: R. T. Millet/President, SAAB-Scania of America, Inc.; H. Gustavsson/BT; N. Gustavsson/BTS; B. Ilhage/BTE; L. Nilsson/BTSL; D. Schwentker/Consul A.I.A.