Interpretation ID: nht75-1.19

DATE: 10/28/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyota Motor Sales, USA, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Toyota's September 5, 1975, request for confirmation that the brake warning indicator labeling requirements in Standard No. 105-75, Hydraulic Brake Systems, permit the use of "PARK" and "SERVICE BRAKE" but prohibit the use of "PARK" and "BRAKE" as labeling for use on two indicator lamps, one signaling the condition of the parking brake system and the other signaling two or more functions of the service brake system. The relevant requirements of S5.3.5 of the standard state:

. . . . If a single common indicator is used, the lens shall be labeled "Brake." If separate indicator lamps are used for one or more of the various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the "Brake" and appropriate additional labeling (use "Brake Pressure," "Brake Fluid" for S5.3.1(a) and S5.3.1(b)) except that if a separate parking indicator lamp is provided, the single word "Park" may be used.

You are correct that S5.3.5 prohibits the use of one indicator labeled "PARK" with another indicator labeled "BRAKE". "PARK" may be used for a separate indicator of the parking brake condition, but only if the other indicator or indicators of brake system condition use the word "Brake" with appropriate additional labeling.

You asked if the designation "SERVICE BRAKE" would be a permissible label on an indicator separate from the "PARK" indicator. The designation would be permissible so long as it describes two or more of the conditions listed in S5.3.1(a), (b), or (c). You will note that S5.3.5 has specific labeling requirements for an indicator which signals only one condition in the case of 1(a), 1(b), and 1(d). In the case of S5.3.1(c), "SERVICE BRAKE" would not be appropriate labeling for the antilock function.

September 5, 1975

Dr. James B. Gregory, Administrator National Highway Traffic Safety Administration U. S. Department of Transportation 400 Seventh Street, S. W. Washington, D. C. 20590

Re: Interpretation of FMVSS No. 105-75, S5.3.5

Dear Dr. Gregory:

We wish to request clarification of our interpretation of S5.3.5, "Brake System Indicator Lamps," of FMVSS No. 105-75, "Hydraulic Brake Systems."

In S5.3.5 it reads as follows: ". . . If a single common indicator is used, the lens shall be labeled "Brake." If separate indicator lamps are used for one or more of the various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word "Brake" and appropriate additional labeling (use "Brake Pressure," "Brake Fluid" for S5.3.1(a) and S5.3.1(b)) except that if a separate parking indicator lamp is provided, the single word "Park" may be used . . . ."

As we interpret it, this requirement does not prohibit the use of a separate indicator lamp for the parking brake labeled "Park" and one for the rest of the brake systems labeled "Service Brake." However, it does prohibit the simultaneous use of two separate indicator lamps labeled "Park" for the parking brake and "Brake" (without any additional labeling) for the other brake system functions, such as those described in S5.3.1(a) and S5.3.1(b).

We would appreciate your informing us of your opinion of our interpretation at your earliest convenience.

Very truly yours, TOYOTA MOTOR SALES, U.S.A., INC.

K. Nakajima Director/General Manager Factory Representative Office

KN:mc