Interpretation ID: nht78-1.11

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 20, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.

Section 5.2.3 of the standard provides that "any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3." There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.

SINCERELY

September 20, 1978

Joseph J. Levin, Jr. Chief Counsel Department of Transportation National Highway Traffic Safety Administration

Subject: Request for Interpretation, FMVSS No. 101-80

Dear Mr. Levin:

According to Federal Motor Vehicle Safety Standard No. 101-80, the speedometers of 1981 and later model year passenger vehicles are to be labelled "MPH" and "km/h". It is our understanding that it is the intent of this requirement, along with FMVSS No. 127, to encourage the use of metric units of speed and distance. It is also the intent of this standard to present information to the vehicle operator as clearly and unambiguously as possible.

Enclosed is a preliminary example of a Volvo proposed speedometer face. Picture A is the proposed 1981 model year speedometer. Note that in this case, the metric unit for speed is labelled "KM/H". In other words, we have used upper case letters, but in exactly the same configuration. We believe that using the upper case letters does not detract from the clarity of the information being conveyed, nor does it discourage use of the metric system. Thus, we interpret the use of "KM/H" to satisfy the requirement of FMVSS No. 101-80.

Please advise us as to whether you agree with our interpretation of this standard. If I can be of any assistance, please feel free to call.

VOLVO OF AMERICA CORPORATION Product Planning and Development

William Shapiro, P.E. Manager, Regulatory Affairs