Interpretation ID: nht71-1.43

DATE: 07/16/71

FROM: ROBERT L. CARTER -- NHTSA MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM -- DIRECTOR AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENT ACTIVITIES STAFF

COPYEE: C.R. SHARP

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in response to your request of June 14 for an interpretation of several provisions of Standard No. 101, Control Location, Identification and Illumination.

You asked first whether "redundant" controls must be identified, such as the windshield washer control that is located in the end of the column mounted shift lever. The standard does not distinguish between required and redundant controls, and redundant controls must be identified. As this agency observed of controls designed to be operable by touch "their function is not clear to a operator unfamiliar with the vehicle in which they are installed, and their identification is necessary" (36 F.R. 8297, May 4, 1971).

Secondly, you pointed out to us the virtual impossibility of requiring identification of intermediate positions in rocker-type and push-pull type heating and air conditioning system controls. We agree with your point, and I enclose an order of the Administrator amending paragraph S4.2 to exclude intermediate positions on these types of controls from the identification requirement.

Finally, you ask whether the identification requirement in S4.2 for "manually operated" controls extends to a floor mounted windshield washer control. Since a manually operated control is, by definition, a control that is operated by hand, a foot-operated control need not be identified.

Sincerely,

Enclosure

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket No. 1-18; Notice 5]

Summary Statement

MOTOR VEHICLE CONTROLS STANDARD - amendment of motor vehicle controls standard (Standard No. 101), to clarify control identification and illumination requirement and control location test condition, effective January 1, 1972, and September 1, 1972.

Title 49 - TRANSPORTATION

Chapter V - National Highway Traffic Safety Administration Department of Transportation

PART 571 - FEDERAL MOTOR VEHICLE SAFETY STANDARDS Control Location, Identification, and Illumination

The purpose of this notice is to amend Motor Vehicle Safety Standard No. 101 to clarify control identification, and illumination requirements, and the control location test conditions.

Standard No. 101, Control Location, Identification, and Illumination, was amended on January 14, 1971 (36 F.R. 503) and, as a result of reconsideration petitions, was amended again on May 4, 1971 (36 F.R. 8296). General Motors Corporation has asked for a clarification of the requirement in S4.2 that "Each position of . . . a heating or air conditioning system control shall be identified." It points out the virtual impossibility of identification of intermediate positions for rocker-type and push-pull-type switches. The NHTSA agrees that intermediate positions for these types of switches are difficult to identify, and consequently has amended S4.2 to exclude them from the identification requirement.

Ford Motor Company has petitioned for a clarification of the requirement in S4.3 that ". . . A control shall be provided to adjust the intensity of control illumination variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify the control under conditions of reduced visibility." Specifically, Ford wishes an interpretation

that a simple on-off switch is a sufficient variable control.

The NHTSA has determined that a motor vehicle operator should be able to set control illumination levels according to his own, eye comfort and the specific condition of reduced visibility that requires control illumination. Additionally, it is important for a driver to reduce control illumination when the illumination is reflected in the windshield creating a glare condition. The NHTSA intended in the January 14 issuance that a continuously variable "rheostat"-type control be provided, and is amending S4.3 to reflect this intention.

The NHTSA is also amending the restraint test condition of S5.2 to correspond with the recent amendment to Standard No. 208, Seat Belt Installations, (36 F.R. 9869) that requires Type 1 seat belt assemblies in, among other vehicles, walk-in van-type trucks, and multipurpose passenger vehicles with a gross vehicle weight rating of more than 10,000 pounds.

In consideration of the foregoing, 49 CFR 571.21, Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification and Illumination, is amended as follows:

1. The third sentence in Paragraph S4.2 is amended to read: "Each position of an automatic vehicle speed control and a heating and air conditioning system control, other than an intermediate position of a rocker-type or push-pull-type control, shall be identified."

2. The last sentence of Paragraph S4.3 is amended to read: "A control shall be provided to adjust the intensity of control illumination, continuously variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify controls under conditions of reduced visibility."

3. Paragraph S5.2 is amended to read: "The person seated at the controls of a multipurpose passenger vehicle or truck with a gross vehicle weight rating of more than 10,000 pounds, convertible, open-body type vehicle, walk-in van-type truck, or bus is restrained by a nonextending pelvic restraint fastened so that there is no slack between the lap belt and the pelvis."

Effective date: January 1, 1972, Paragraph S4.2 for passenger cars; September 1, 1972, Paragraph S4.2 for vehicles other than passenger cars, Paragraph S4.3 and Paragraph S5.2.

This amendment is issued pursuant to sections 103 and 119 of the National Traffic and Motor Vehicle Safety Act of 1966, and the delegation of authority from the Secretary of Transportation to the National Highway Traffic Safety Administrator, 49 CFR 1.51.

Issued on JUL 9 1971

Douglas W. Toms

Acting Administrator