Interpretation ID: nht81-3.22

DATE: 10/06/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Honda Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 27, 1981, asking about Federal Motor Vehicle Safety Standard No. 101-80. Your letter asked whether an enclosed sample of a heater control identification plate met the requirements of section S5.2.2 of the standard. Your letter was primarily concerned about whether the color used for the hot extreme would be considered "red" within the meaning of that section.

The sample heater control identification plate enclosed with your letter identifies the hot and cold extremes of the temperature control by both words and color. At the left of the identification plate is the word "cold" on a blue background. At the right of the identification plate is the word "hot" on a background that appears by visual inspection to be orange.

Section S5.2.2 of Standard No. 101-80 states:

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. If this identification is not specified in Tables 1 or 2, it shall be in word form unless color coding is used. If color coding is used to identify the extreme positions of a temperature control, the hot extreme shall be identified by the color red and the cold extreme by the color blue . . . . [Emphasis added.]

The agency interprets section S5.2.2 to require that the colors red and blue be used to identify the extreme positions of a temperature control only when color is the sole means by which the extreme positions are identified. If the words "hot" and "cold" are used to identify the extreme positions, color coding is a voluntary addition and the red and blue color requirements of section S5.2.2 do not apply.

Therefore, since the sample of the heater control identification plate enclosed with your letter identifies the extreme positions of the temperature control with the words "hot" and "cold," it meets the requirements of section S5.2.2 concerning that requirement regardless of whether the color used for the hot extreme would be considered "red" within the meaning of that section.

As to your question whether the color used for the hot extreme on the sample of the heater control identification plate is red, our visual inspection indicates that the color is orange rather than red. For guidance on the meaning of the color "red," we suggest that you refer to 49 CFR @ 172.407(d). That section, which is part of the Department of Transportation's regulations concerning hazardous materials, establishes color tolerances for various colors, including red. The section indicates how to obtain copies of the Department's color tolerance charts or where they may be inspected. While the charts are not referenced by Standard No. 101-80, they do provide guidance on the tolerances of various colors.

SINCERELY,

AMERICAN HONDA MOTOR CO., INC.

July 27, 1981

Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Sir:

This is to request your official interpretation regarding the red color to be used on the heater temperature control identification plate.

In FMVSS 101-80, section S5.2.2 requires in part that the hot extreme of the heater temperature control shall be identified by the color red; if color coding is used.

I am enclosing a sample of the heater control identification plate which we intend to use on 1982 model year Honda automobiles for your inspection. Please confirm that the color used for the hot extreme meets your requirements.

Brian Gill Manager Certification Department

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