Interpretation ID: aiam2754
Legislative Engineer
NVT Motorcycles Limited
Lynn Lane
Shenstone
Lichfield
Staffordshire WS14 OEA
England;
Dear Mr. Henderson: This is in reply to your letter of December 15, 1977, asking for a interpretation of S5.1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*. You have asked whether a switch on the right handlebar of moped exported by NVT to the United States may be viewed as the 'supplement engine stop control' that the standard requires.; You have noted that the switch is 'identified as required in Table 3 and that the engine can be stopped by the clutch that is part of the starter arrangement. To answer your question it is necessary to make several assumptions as your letter is not complete enough to allow a definitive response. If the normal or recommended method of stopping the vehicle is through the clutch then the switch may serve as the supplemental engine stop control. If, however, turning the switch to off is the normal or recommended method of stopping the vehicle, it cannot be viewed as a supplemental control.; We assume that the switch is identified as 'engine stop' and no 'ignition' since you refer to it as a means of stopping the vehicle and imply that the clutch arrangement is the only method of starting it. If our assumptions are not correct, please inform us of the correct facts so that we may advise you accordingly.; Sincerely, Joseph J. Levin, Jr., Chief Counsel