Interpretation ID: nht74-1.9

DATE: 03/15/74

FROM: AUTHOR UNAVAILABLE; J. B. Gregory; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of November 19, 1974, petitioning the NHTSA to amend Part 567, Certification (@ 567.4(f)), to allow the use of certification labels on which the lettering is embossed or engraved without regard to whether it contrasts with its background.

The NHTSA has decided that your petition should be denied. Our experience has been that certain types of engraving, those that are stencil-typed or stamped, are difficult to read without color contrast. The NHTSA considers it essential that certification labels be readable under all lighting conditions, and has not found embossing or engraving to produce by themselves sufficiently readable lettering for these labels. Of course, there is no prohibition against embossing or engraving if the finished lettering contrasts with its background.

We appreciate your point that Standard No. 105a accepts embossed or engraved lettering on the master cylinder reservoir label without requiring a color contrast. We are presently considering amending Standard No. 105a to eliminate this discrepancy.