Interpretation ID: nht78-1.12

DATE: 12/29/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: R. E. Dietz Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 21, 1978, requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

In your first set of questions, you ask about the application of the display requirements to trucks with a GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.

In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is "no." S5.2.1 provides that the symbol shall be placed on or adjacent to the control. You also ask if there is any size requirement. The answer is again "no." There are no size requirements for any of the control symbols.

In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand-operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the nonmandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.

In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.

SINCERELY,

R. E. DIETZ COMPANY

September 21, 1978

Nelson Erickson Office of Motor Vehicle Programs

Dear Mr. Erickson:

This is a request for further information and clarification of new rule 49 CFR 571.101-80 Controls and Displays.

Our questions and concerns pertain principally to our new 16-35 turn signal switch (drawing enclosed), which went into production this year. This type of hang-on switch is used only on Class 7 trucks which are in the weight range of 26,001 to 33,000 pounds GVWR and Class 8 trucks which are over 33,000 pounds GVWR.

1. I understand that since Class 7 and 8 trucks exceed 10,000 pounds GVWR, display requirements of 55.1 in Column 1 of Table 2 do not apply. Is that correct?

2. If correct, then do Columns 3 and 4 apply?

3. If Column 3 applies, then FMVSS 108 sends us to SAE J-589 for turn signal switches which references J-588, which calls for an illuminated area (shape unidentified) equivalent to a 3/16" diameter circle. Is that correct?

4. Column 3 also sends us to FMVSS 108 which refers us to J-910 for hazard switches, which calls for an illuminated area (shape unidentified) equivalent to a 1/2" diameter circle. Is that correct?

If the above statements are correct, then 571.101-80 (in which "the agency has decided that vehicles over 10,000 pounds GVWR need not meet display requirements of this standard") seems to be retaining display requirements. It appears that the intent is that neither Column 3 nor 4 are meant to apply. Is that correct?

Regarding identification and illumination of controls -

1. Would you say that double arrows on the device meet the requirements? If not, is it necessary that they be printed on the lever itself? If so, can they be on the lever axis or must they be on the arc which a point on the lever travels when the lever is moved to the right or left turn position. If there any size requirement?

2. As you can see from our drawing, there is approximately 5/8" of hazard button which extends out from our lever. The thickness of the button varies from 3/16" at the bottom to 1/16" at the top. What size does the identifying symbol have to be? If we could find a plastic which would transmit some light out to the end, would that be considered meeting the specification? If we cannot find a design solution to this requirement, what recourse do we have short of a complete re-design and re-tooling?

3. Finally, I must ask again for clarification of the relationship between 571.101-80 and FMVSS 108. It appears that one could meet all of the requirements of 571.101-80 but be found failing to conform to FMVSS 108. Is it the intent of 571.101-80 to be an addition to the requirements of FMVSS 108.

Your earliest response to these questions would be appreciated since it appears that we may have some significant changes to make.

Donald W. Vescio, Sr. Director of Engineering

(Illegible Lines)

UNLESS OTHERWISE SPECIFIED THE FOLLOWING (Illegible Words)

THREE PLACE DECIMALS (Illegible Word) .006

TWO PLACE DECIMALS (Illegible Word)

DIETZ (registered) R.E. DIETZ CO. SYRACUSE N.Y.

TITLE: 16+35 TURN SIGNAL SWITCH ASSEMBLIES SHEET: 016-35600

3. 16-35 TURN SIGNAL SWITCH IS DESIGNED TO CONFORM TO SAE J 589(b), SAE J 910(b) AND SAE J 588 (e) PARAGRAPH 4.5. IT CONFORMS WITH FMVSS 108 AND IS DESIGNED TO MEET NEW PROPOSED FMVSS STANDARDS FOR PILOT INDICATORS.

HAZARD BUTTON (Illegible Word) PLASTIC

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