Interpretation ID: nht80-3.38

DATE: 08/25/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Renault USA

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION August 25, 1980

Mr. Francois Louis Head of Governmental Affairs Renault USA 14250 Plymouth Road Detroit, Michigan 48232

Dear Mr. Louis:

This responds to your letter of July 14, 1980, seeking an interpretation of Standard No. 101-80, Controls and Displays. You asked whether an engine stop control mounted on the engine cover of a cab-over-engine truck must be illuminated. The answer is no, it need not be illuminated.

Section S5.3.1 of the standard provides that except for "foot-operated controls or hand-operated controls mounted upon the floor, floor console or steering column, " any control listed in column 1 of Table 1 and accompanied by the word "yes" in column 4 shall be capable of illumination whenever the headlights are activated. Since the engine stop control is listed in column 1 of Table 1 and accompanied by the word "yes" in column 4, it must be illuminated, unless it falls within one of the exceptions of S5.3.1.

In the case of the engine stop control in your truck, the control is located on the engine cover. Because the engine cover is separate from the instrument panel and mounted on the floor between the two front seats, the agency considers it a floor console. Thus, the engine stop control located on the cover does not have to be illuminated.

I would like to emphasize that oral interpretations by agency staff are only unofficial opinions. Therefore, if you have questions in the future, they should be directed at the outset in writing to this office.

If you have any further questions, please let me know.

Sincerely, Frank Berndt Chief Counsel

July 14, 1980

Mr. Frank Berndt

Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W. Washington D.C. 20590

Dear Mr. Berndt:

This letter is to seek NHTSA's confirmation of the following interpreration given to us orally, by Mr. John Carson of the Rulemaking Staff:

"The engine cover of a cab-over-engine truck depicted on the attached drawing constitutes a floor console, and, therefore, under the provisions of paragraph S5.3.1 of FMVSS 101, the engine stop control mounted thereon need not be illuminated."

We would appreciate confirmation at your earliest convenience.

Sincerely.

Mr. Francois Louis Head of Governmental Affairs

Mr. Francois Louis Head of Governmental Affairs Renault USA 14250 Plymouth Road Detroit, Michigan 48232

Dear Mr. Louis:

This responds to your letters of July 14, 1980 seeking an interpretation of Standard No. 101-80, Controls and Displays. You asked whether an engine truck must be on the engine cover of a cab-over-engine truck must be illuminated. The answer is no, it need not be illuminated.

Section S5.3.1 of the standard provided that except for "foot-operated controls or hand-operated controls mounted upon the floor, floor console or steering column," any control listed in column 1 of Table 1 and accompanied by the word "yes" in column 4 shall be capable of illumination whenever the headlights are activated. Since the engine stop control is listed in column 1 of Table 1 and accompanied by the word "yes" in column 4, it must be illuminated, unless it falls within one of the exceptions of S5.3.1.

In the case of the engine stop control in your truck, the control is located on the engine cover. Because the engine cover is separate from the instrument panel and mounted on the floor between the two front seats, the agency considers it a floor console. Thus, the engine stop control located on the cover does not have to be illuminated.

** I would like to emphasize that oral interpretations by agency staff are only unofficial opinions. Therefore, if you have questions in the future, they should be directed at the outset in writing to this office.

If you have any further questions, please let me know.

Sincerly,

Frank Berndt Chief Counsel

NOA-30:SLOesch:pfp:8/6/80 cc: N)A-30 Subj/Chron, NOA-30 Mr. Oesch NEF-30, NRM-10, Interps: Std Redbook: (3) cc-963 1a

**NOTE: During the phone call Mr. Louis was advised that any remarks or opinions by the engineer were purely personal and that he must write to the Office of Chief Counsel for an official interpretation. This is standard procedure whenever anyone calls about an interpretation of a standard