Interpretation ID: 2791y
Design Engineer
VDO-YAZAKI Corporation
l773 Star-Batt Drive
Rochester Hills, MI 48309
Dear Mr. Long:
This responds to your letter asking about requirements concerning two proposed automotive instrument panel telltale warnings. I apologize for the delay in this response.
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 motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.
Your first proposed telltale design is for "4 wheel antilock brake application." The design would include a picture of a skidding car and the letters "4W ABS." You asked whether this telltale would fulfill applicable requirements or whether the ISO "ABS" symbol must be used.
Standard No. l0l, Controls and Displays, requires that new vehicles with any display listed in the standard must meet specified requirements for the location, identification and illumination of such display. In addition, certain other standards, including Standard No. l05, Hydraulic Brake Systems, include requirements relating to vehicle displays.
Standards No. l0l and No. l05 include several requirements for telltales indicating malfunction in an antilock brake system. Copies of these standards are enclosed for your convenience. Among other things, these standards specify the following identifying words or abbreviation for an antilock malfunction telltale: "Antilock, Anti-lock or ABS." The standards also permit additional words or symbols to be used for the purpose of clarity. See section S5.2.3 of Standard No. l0l and section S5.3.5(a) of Standard No. l05.
It is unclear from your letter whether your proposed telltale would indicate "malfunction" in an antilock brake system, since you describe it as indicating "4 wheel antilock brake application." If the telltale is for antilock malfunction, it would appear to meet the requirements specified in Standards No. l0l and No. l05 for identifying words or symbols, since it includes the abbreviation "ABS," and the other words/symbols can be considered to be for the purpose of clarity. Of course, the telltale would also need to meet the other requirements specified in those standards, e.g., size of letters, color, etc.
If the telltale does not indicate antilock malfunction, e.g., it only indicates when the antilock system is activated during braking, no requirements would apply to the telltale. Unless a particular telltale is listed in Standard No. l0l (or is covered by another standard), no requirements apply to such telltale. If the telltale does not indicate antilock malfunction, however, I would suggest that you consider whether drivers would confuse the telltale with the required telltale for antilock malfunction.
Your second proposed telltale is for warning against hazardous emissions from the vehicle. Your design would include an outline of an engine and the word "CHECK." You asked whether the word "CHECK" is necessary, and whether the engine outline is an approved ISO symbol.
NHTSA does not have any requirements for a telltale warning against hazardous emissions from the vehicle. However, we suggest that you check with the Environmental Protection Agency and the California Air Resources Board as to whether they have any requirements (or are developing requirements) concerning such a telltale. You may contact those agencies at the following addresses:
Environmental Protection Agency Office of Mobile Sources Certification Branch 2565 Plymouth Road Ann Arbor, Michigan 48l05
Air Resources Board Certification Section 9528 Telstar Avenue El Monte, California 9l73l
I hope this information is helpful.
Sincerely,
Paul Jackson Rice Chief Counsel /Enclosures ref:l01#105 d:12/17/90