Interpretation ID: 86-2.18
TYPE: INTERPRETATION-NHTSA
DATE: 04/09/86
FROM: NIROSHI NORIYOSHI -- EXECUTIVE VICE-PRESIDENT AND GENERAL MANAGER MAZDA
TO: ERIKA Z. JONES -- OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION DEPARTMENT OF TRANSPORTATION
TITLE: REQUEST FOR INTERPRETATION - FMVSS 101; CONTROLS AND DISPLAYS AND FMVSS 102; TRANSMISSION SHIFT LEVER SEQUENCE, STARTER INTERLOCK, AND TRANSMISSION BRAKING EFFECT
ATTACHMT: ATTACHED TO LETTER DATED 12/24/86 TO HIROSHI MORI YOSHI FROM ERIKA Z JONES, REDBOOK A29 (4), STD 101 AND 102
TEXT: Dear Ms. Jones:
Mazda (North America), Inc., on behalf of Mazda Motor Corporation, requests interpretation of certain provisions of FMVSS 10:, Controls and Displays and FMVSS 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. The specific provisions relate to the conditions of visibility for the gear position indicator of an automatic transmission.
Mazda is considering the application of LED's located within the instrument panel for use in automatic transmission gear position identification. The envisioned system would conform with all applicable requirements when the ignition switch is in the on and start position, but would not otherwise be visible when deactivation of the vehicle's main electrical system occurred by placing the ignition switch in the accessory or off position. The gear shift selector, mounted on the steering column, would be provided with embossed position indicators conforming to FMVSS 102, except that the identifiers would only be visible from the side of the steering column and thereby require the driver to lean forward and to the right for visual confirmation of the automatic gear position.
FMVSS 101.5(a) requires, by way conference to Table 2, the automatic gear position indicator of a vehicle meet the requirements of the standard for location, identification, and
illumination. Specifically, the automatic gear position indicator must be visible to a driver restrained by the crash protection equipment provided and adjusted in accordance with the manufacturer's instructions. FMVSS 102.3.2 additionally requires the shift lever position indicator of automatic transmissions be displayed in view of the driver.
In past interpretations requested by Ford and Porache, the Agency has concluded that FMVSS 102.3.2 requires the gear position indicator to be visible regardless of the operating mode of the engine. However, the Agency has not had an opportunity to consider the case of multiple and complementary indicators that individually may not be in conference with the Standards, but collectively would in fact provide indication of gear selection "permanently in view of the driver". The systems would complement each other by providing a clear and unmistakable indication directly before the driver when the engine is activated and by providing a permanent visual cue that can be accessed with little inconvenience by the driver in all other circumstances. Therefore, Mazda believes this system would conform with the applicable provisions of FMVSS 101 and 102.
Accordingly, Mazda requests that the Agency consider our conclusion and comment on the determination that this combination of indicators can be considered "permanently displayed in view of the driver". Also, please clarify the meaning of "view of the driver". It is now possible, with the use of emergency locking retractors, that the driver may lean forward and later return to the normal driving posture with no "misadjustment" of the vehicle's restraint system. Under such conditions, would the embossed automatic gear selection identifiers be considered within the driver's field of view while the vehicle is not activated? Please discuss your conclusion.
Thank you for your consideration of this issue. Mazda is aware that the Agency is not able to approve actions taken by manufacturers. However, we do desire to obtain the opinion of the Agency in this matter. Should you have any questions, please contact Mr. Ken Tashima at the address or telephone number above.
Sincerly,