Interpretation ID: nht81-1.25

DATE: 03/05/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gillig Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Mr. Roy O. Smith

Manager of Body Design Gillig Corporation Box 3008 Hayward, California 94540

Dear Mr. Smith:

This responds to your letter of November 20, 1980, inquiring about Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked for our confirmation that a foot-operated turn signal control on your new transit bus is not subject to the identification requirements of Section S5.2.1.

The identification requirements of Section S5.2.1 of Safety Standard No. 101 are applicable to "hand operated" controls. Since the turn signal control on your new transit bus is foot operated, those requirements are not applicable. Since the standard does not include any other identification requirements for turn signal controls, your conclusion stated above is correct.

While the identification requirements of Section S5.2.1 are not applicable to your transit bus, you may wish to identify the turn signal control in some manner in order to prevent confusion when persons unfamiliar with foot-operated turn signal controls operate your transit bus.

The agency is currently conducting research on the standardization of the location of critical controls, including the turn signal control. We would appreciate receiving information as to why you are locating the turn signal control on the floor when the vast majority of other vehicles have the control mounted as a stalk on the steering column.

We would also note that Standard No. 101's display requirements for turn signals are applicable to your transit bus if it has a GVWR of under 10,000 pounds. Also Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, includes other requirements related to turn signals.

Sincerely,

Frank Berndt Chief Counsel

November 20, 1980

Mr. Frank Berndt CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

On our new transit bus, we use foot actuated push buttons to operate the turn signals. Section S5.2.1, (a) of Federal Motor Vehicle Safety Standard 101-80, requires that "Any hand operated control listed in column 1 of Table I that has a symbol designated in column 3 shall be identified by that symbol".

Since our turn signal control is foot operated, not hand operated, it is our opinion that this requirement does not apply to our arrangement. Your comments would be appreciated.

Very truly yours,

GILLIG CORPORATION

Roy O. Smith

Manager of Body Design

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