Interpretation ID: nht80-1.7

DATE: 01/25/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Grumman Flexible Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. In a telephone conversation with Ms. Debra Weiner of my office, you asked whether section S5.2.2 of the standard would apply to the windshield wiper controls which Grumman Flexible intends to install in its transit buses. As I understand your description, there are to be separate controls for the left and right windshield wipers and each control will allow for operation of the wiper over a continuous range of speeds.

The answer to your question is no. Section S5.2.2 of Standard 101-80 provides that:

Identification shall be provided for each function of any automatic vehicle speed system control and any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. (emphasis added).

The function identification requirements are not applicable since their applicability is expressly limited to speed controls and to heating and air conditioning controls. The applicability of the extreme position identification requirements is similarly limited since "such controls" refers back to those controls already identified in S5.2.2.