Interpretation ID: nht87-1.7

TYPE: INTERPRETATION-NHTSA

DATE: 01/09/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Lewis H. Goldfarb -- Assistant General Counsel, Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Lewis H. Goldfarb, Esq. Assistant General Counsel Chrysler Corporation P.O. Box 1919 Detroit, Michigan 48288

This responds to your letters asking about Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, with regard to a design you are considering producing. You asked whether the standard's requirement that identification of shift lever positions of automatic transmissions shall be permanently displayed in view of the driver would be met by an electronic display that is activated for three minutes after the driver's door b open, whenever the key is in the ignition switch, and for three minutes after the key is removed from the ignition switch. You later asked about a variation of the proposed design. Noting that drivers sometimes leave the key in the ignition switch for long per iods of time, you stated that you planned to incorporate a timing device which would shut off the illumination after 15 minutes if the key is left in the ignition switch and the ignition switch remained in either the "lock" or "off" position. As discusse d below, it is our opinion that neither of your proposed designs would meet the standard's requirement for permanent display in view of the driver.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

Section S3.2 of Federal Motor Vehicle Safety Standard No. 102 requires that the "(i)identification of shift lever positions of automatic transmissions and of the shift lever pattern of manual transmissions . . . shall be permanently displayed in view of the driver." (Emphasis added) NHTSA has previously interpreted this provision as requiring a display that can be seen regardless of the operating mode of the engine. Thus, it is not permissible for the display to be visible (e.g., in the case of an elect ronic display, be activated) only when the key is in the ignition switch.

Your letter raises the issue of whether it is permissible for an electronic display to become activated at the time the driver enters the car and, if so, whether it must remain activated indefinitely as long as the driver remains in the car, even if the ignition is not turned on. is our opinion that is permissible for an electronic display to become activated at the time the driver enters the car and need not be activated when there is no person in the driver's seating position. Section S3.2's requireme nt that the identification of shift lever positions of automatic transmissions be "permanently displayed" is modified by the phrase "in view of the driver." It is our opinion that no such display is required at times when no driver is in the car, i.e., n o person in the driver's seating position. We also conclude, however. that such a display must remain activated indefinitely as long as the driver remains in the driver's seating position even if the ignition is not turned on. If the display only remaine d activated for a specific period of time, such as three minutes or 15 minutes, it would not be "permanently" displayed.

Sincerely,

Erika Z. Jones Chief Counsel

October 7, 1986 Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington. D.C. 20590

Re: Confirmation of Interpretation of MVSS 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect

Dear Erika:

Chrysler Motors Corporation requests confirmation of our interpretation that the PRNDL display in a new electronic cluster we are designing for one of our 1990 model vehicles meets the requirements of paragraph S3.2 of MVSS 102, "Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect." That paragraph states in part that "Identification of shift lever positions of automatic transmissions...shall be permanently displayed in view of the driver."

We believe this provision is intended to provide that the PRNDL should be displayed to a person in the driving position for the purpose of operating the vehicle. It is not intended, however, to require the display of the PRNDL when there is no one engage d in operating or "driving" the vehicle and where the continuous lighting of an electronic PRNDL display would be a serious drain on the vehicle's battery.

In our new electronic instrument cluster design, the PRNDL display illuminates and displays the transmission gear position as soon as the driver's door is opened. This feature provides the driver an immediate indication of the position of the transmissio n gear selector just as does a conventional "mechanical" PRNDL indicator. With our design the transmission gear selector position will continue to be lighted if the ignition key is inserted into the ignition lock cylinder within approximately three minut es. The only difference between our electronic PRNDL display and a mechanical one is that, to save battery strength when the vehicle is not being driven, our electronic indicator will turn off after three minutes unless the driver inserts the key in the ignition key cylinder.

Should the PRNDL display turn off after a three minute period, however, inserting the ignition key will cause it to come on immediately, and it will remain on as long as the key is in the ignition switch. The three minute period is more than sufficient t ime to allow the driver to get settled in the seat, fasten the safety belt, and insert the ignition key. When the trip is completed and the key is removed from the ignition lock, the PRNDL display remains lighted for approximately three minutes while the driver unfastens safety belts, picks up articles, exits, and locks the vehicle.

We believe that the design of our electronic PRNDL display meets the intent as well as the needs of motor vehicle safety as stated in the requirements of paragraph S3.2 of MVSS 102.

In summary, the shift lever position will be displayed to the driver while the driver enters the vehicle, while the ignition key is in the ignition lock, and while the driver exits the vehicle.

We would appreciate your early consideration and confirmation of this interpretation.

Sincerely,

Lewis H. Goldfarb

CC: R. O. Sornson