Interpretation ID: nht90-3.2

TYPE: Interpretation-NHTSA

DATE: June 28, 1990

FROM: Satoshi Nishibori -- Vice President, Industry-Government Affairs, Nissan Research & Development, Inc.; Signature by Kazuo Iwasaki

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-18-90 from P.J. Rice to S. Nishibori (A36; Std. 101)

TEXT:

This letter is to request NHTSA's interpretation of how the requirements of FMVSS 101 (Controls and Displays) would apply to two vehicle systems that Nissan is considering using. These systems are described below.

I. Car Phone

Nissan is considering offering a car phone for use in certain of its passenger cars. The car phone would be installed in the vehicle's console, in the lower, forward portion of the driver's field of vision. The car phone would have five visual displays, each of which is bright enough to be seen under all ambient lighting conditions. The illumination for these displays is not variable and the system may not be turned off while the vehicle ignition switch is in the "ON" position.

The first display shows the number that is being dialed (see Figure) through an LED. This display is illuminated whether or not the telephone is in use, and the number being dialed is shown during the time that the phone is in use.

The second display illuminates the push buttons for dialing numbers. This display is illuminated when the first button is pushed when dialing a number, and the display remains illuminated for a period of ten seconds.

Finally, the system uses three LED indicators. The first indicator (IU) is illuminated when the phone is "in use." The second indicator (NS) is illuminated when the system is outside an area where cellular phone service is available (i.e., "no service" ), as determined by the failure of the system's "roaming" function to lock on an available phone line. The third indicator (RM) is illuminated when this "roaming" function is operating, when outside the system's local operating area.

It is our understanding that this phone system would comply with FMVSS 101 requirements if the five information displays are considered to be "telltales." The term "telltale" is defined in section 4 of FMVSS 101 as "a display that indicates the actuatio n of a device, a correct or defective functioning or condition, or a failure to function." Since the displays used in the phone system indicate operation of various functions of the phone system, the displays may meet the definition of "telltale" in sec tion 4 of the standard. If so, the system would appear to be consistent with the requirement for telltales in section 5.3.4(a) of FMVSS 101, since the illumination of the displays is bright enough to be visible under all ambient lighting conditions. On the other hand, the system would not appear to meet the requirements of section 5.3.5 of the standard

if the displays are considered to be other "sources of illumination," since the displays do not have variable illumination, are brighter than "barely discernible" in night conditions, and may not be turned off without shutting off the vehicle.

Please inform us whether the displays used in this car phone system are "telltales" or other "sources of illumination," and whether the system is consistent with the requirements of FMVSS 101.

II. Air-conditioning Indicator Light

In certain vehicles, Nissan uses an indicator light that is illuminated whenever the air-conditioning system operating switch and the ignition switch are in the "ON" position. When the air conditioner or the ignition switch is turned "OFF," the indicato r light is extinguished.

Nissan believes that the air conditioner indicator qualifies as a "telltale," since it indicates the "actuation of a device." If the air conditioner indicator display is considered to be a "telltale," it would appear to meet the requirements of section 5.3.4, since the display is bright enough to be visible in all ambient lighting conditions.

On the other hand, this display would appear to be comparable to the radio display that is described in NHTSA's January 7, 1988, letter to Isuzu. In that letter, the Agency concluded that the illuminated radio display is considered to be one of the other "sources of illumination" in section 5.3.5 of FMVSS 101. Since the radio display can be turned off by turning off the radio, NHTSA considered it to be consistent with section 5.3.5(3). In the same manner, the air conditioner indicator display can be tu rned off by shutting off the air conditioner system. The radio display referred to in the Isuzu interpretation would also seem to meet the "telltale" definition, although the radio display serves the function of aiding tuning of the radio in addition to indicating whether the device is operating.

Please inform us as to whether the proposed air conditioner lighting display is considered to be a "telltale" or an "other source of illumination" under section 5.3.5 of the standard, and whether the display would be consistent with applicable requiremen ts.

If you require further clarification regarding the proposed Nissan systems, please contact Mr. Kazuo Iwasaki of my staff at 202/466-5284.

(Drawing attached).