Interpretation ID: nht74-3.1

DATE: 07/30/74

FROM: RICHARD B. DYSON -- NHTSA ACTING CHIEF COUNSEL

TO: P. K. KAMATH -- SENIOR SAFETY ENGINEER OSHKOSH TRUCK CORPORATION

TITLE: N40-30 [ZTV]

ATTACHMT: LETTER DATED 07/09/74 FROM P.K. KAMATH TO RICHARD DYSON -- NHTSA, 49CFR PART 571 FMVSS 101; CONTROL LOCATION, IDENTIFICATION AND ILLUMINATION

TEXT: Dear Mr. Kamath:

This is in reply to your letter of July 9, 1974, asking whether Standard No. 101 requires identification and illumination of an emergency engine stop control, in addition to the engine stop control intended for normal use.

The "engine stop" control referred to in Standard No. 101 means any control used to stop the engine, and would include the emergency control. If it is important for the normal control to be identified and illuminated, it is all the more important that a control intended for emergency use meet the requirements of the standard. Identification such as "emergency engine stop" would be acceptable under Standard No. 101. Illumination, of course, must meet the requirements of the standard, but since you have not described the emergency system or its location we cannot offer a more precise comment.

Yours truly,