Interpretation ID: nht78-1.48

DATE: 12/29/78

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

TO: Ford Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Dec. 29, 1978

NOA-30

Mr. J. C. Eckhold, Director Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Eckhold:

This is in response to your letter of August 29, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80. The answers to your specific questions are as follows:

(1) You requested an interpretation that a single telltale which monitors both the oil pressure and coolant temperature gauges could be identified by the word "Engine." You indicated that it has been Ford's practice to combine the monitoring of these two functions into a single telltale because the response by the driver to either malfunction is the same. The standard does not require that any of the displays listed in S5.1 be provided or that two or more displays, if provided, be provided separately. It is the interpretation of the NHTSA that the multipurpose telltale which monitors the two functions specified above may be identified by the word "Engine."

(2) You asked whether the NHTSA intended that the display identification requirements of FMVSS 208 would be met by use of the symbol required by FMVSS 101-80. The answer is no. However, the agency will issue shortly a notice which will provide for the use of the FMVSS 101-80 symbol for the purposes of that standard and those of FMVSS 208.

(3) You asked that the identification requirements of FMVSS 105-75 be deleted from that standard and those in FMVSS 101-80 be retained. No conflict exists between the two standards. Nevertheless, we will address this issue in the same notice mentioned in the immediately preceding paragraph.

Sincerely,

Joseph J. Boyin, Jr. Chief Counsel

Ms Joan B. Claybrook Administrator National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook:

Re: Request for Interpretation of Federal Motor Vehicle Safety Standard No. 101-80

Ford Motor Company requests clarification of three of the provisions in Federal Motor Vehicle Safety Standard (FMVSS) 101-80, Controls and Displays, as amended (Fed. Reg. 27541, et seq., June 26, 1978). The need for such clarification became evident to Ford following a review of the final rule and its implications to future model designs.

1. Engine Coolant Temperature and Oil Pressure

Ford believes that the words in S5.1 of the Standard; ". . . each of the following displays that is furnished . . ." (emphasis added) were incorporated to distinguish between those descrete and distint displays required to use a specific word(s) or symbol and "others", such as a single telltale covering both engine coolant temperature and oil pressure, not covered by the regulation. This conclusion is consistent with Ford's comments in Attachment 1 of its response to Docket No. 1-18; Notice 12 (41 Fed. Reg., 46460 et. seq.) where Ford noted that for several years it has, with satisfactory results, combined the display for adverse conditions of either of these functions with a single telltale labeled with the word *Engine". In our 1978 Fairmont and Zephyr vehicle lines we are using a symbol instead of the word "engine" (see attachment). When the "engine" telltale glows steadily, the advice given in our Owners Manual is the same for either low oil pressure or high coolant temperature: "Pull off the road and stop the engine immediately and determine the cause. If the engine is not stopped immediately, severe damage could result."

We request confirmation of our belief that a telltale, with a single symbol or word, monitoring both the engine coolant temperature and the oil pressure may be used.

2. Seat Belt Warning System

S5.2.3 of FMVSS 101-80 requires the use of the symbol for the seat belt warning telltale shown in Column 4 of Table 2, while the requirement of S4.5.3 and S7.3 of FMVSS 208 is for a warning system displaying the words "Fasten Seat Belts" or "Fasten Belts". Because the preamble to the amended 101-80 Standard states that "It is also proposed to consolidate the control and display requirements of other standards in one regulation. This notice takes final action on that proposal...." Ford believes that the Administration intended that the identification requirements of FMVSS 208 would be met by the symbol required in FMVSS 101-80 -- and use of the words "Fasten Seat Belts" or "Fasten Belts" is optional. Ford, therefore, requests confirmation of its belief and recommends that FMVSS 208 be amended to delete the labeling requirements for seat belt warning indicators in order to remove this inconsistency.

3. Brake warning System

For the same reason noted in 2 above, a clarification of the warning lamp requirements for brake systems in FMVSS 105-75 is requested. FMVSS 105-75, Section 5.3., et seq., requires a warning lamp for brake system failure, brake light proveout and parking brake "ON". In addition, FMVSS 105-75 specifies the manner in which this warning lamp must be displayed, i.e., a red lens and the word "BRAKE". Telltale requirements are also specified in FMVSS 101-80. Ford believes that the identification requirements of the brake system warning lamp should be deleted from FMVSS 105-75 and retained in FMVSS 101-80. This method of requiring the presence of a warning lamp in a system standard and specifying the form of the display in FMVSS 101-80 Would then be consistent with other standards requiring warning lamps.

In reviewing Table 2 of FM7SS 101-80, we have identified certain minor anomalies. Column 3 of Table 2 incorrectly references FMVSS 105 instead of FMVSS 121 for brake air pressure. In addition, Brake System only references FMVSS 121 in Column 3 but should also include FMVSS 105-75.

Finally, to be consistent with other reference ????????? standards, we suggest a reference to FMVSS 127 to be ???????? the speedometer and odometer displ ???????? Very truly yours,

J. C. Eckhold Director Automotive

**INSERT ATTACHMENT** FORD SYMBOL USED ON A SINGLE TELL-TALE FOR ENGINE OIL PRESSURE AND COOLANT TEMPERATURE