Interpretation ID: nht72-6.58

DATE: 01/26/72

FROM: RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL NHTSA

TO: E. R. STERNBERG -- DIRECTOR ENGINEERING PLANNING - TRUCK GROUP WHITE MOTOR CORPORATION

COPYEE: DYSON; VINSON

TITLE: 40-30

ATTACHMT: LETTER DATED 1/3/72 FROM E. R. STERNBERG -- ENGINEERING PLANNING TRUCK GROUP WHITE MOTOR CORPORATION TO DOCKET ROOM NHTSA

TEXT: Dear Mr. Sternberg:

This is in reply to your letter of January 3, 1972, requesting an interpretation of S4.2.2 of Standard No. 101, as it applies to your proposed method of compliance for push-pull controls.

S4.2.2 requires, in pertinent part, that "Identification shall be provided for each function of any . . . heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range." Identification such as that shown in your Example (2) would meet Standard No. 101, while the identification provided in Example (3) would not. Legends such as "Pull on" and "Push off" might more clearly indicate control positions than your suggested "Max (out)" and "Off (in)." The control which operates both the defroster and heater must identify both functions; "Defrost" as indicated is insufficient. Legends such as "Pull to defrost" and "Push for heat" would be acceptable for conformance.

Sincerely,