Interpretation ID: nht90-1.62

TYPE: Interpretation-NHTSA

DATE: March 5, 1990

FROM: Jeffrey Donaldson -- Human Factors Engineer, Arcad

TO: Steve Wood --Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-17-90 from P.J. Rice to J. Donaldson (A36; Std. 101)

TEXT:

In a March 2, 1990 phone conversation with Mr. Roman Brooks, he instructed me that any questions concerning motor Vehicle Safety Standards (MVSS) 101 were to be submitted in writing to you.

My inquiry is in reference to MVSS 101 and its application to the Instrument Panel Illumination Intensity Control (Dimmer Switch). Paragraph S5.1 reads as such:

"S5.1 location. Under the conditions of S6, each of the following controls that is furnished shall be operable by the driver and each of the following displays that is furnished shall be visible to the driver. Under the conditions of S6, telltales are c onsidered visible when activated."

Later in paragraph S5.3.3 (a):

"S5.3(a) Means shall be provided for making controls, gauges, and the identification of those items visible to the driver under all driving conditions."

Given these statements, the question remains, is the instrument panel illumination intensity control required to be visible to the driver under the requirements of MVSS 101?

I appreciate your prompt attention to this and look forward to your response. Please feel free to contact me at (313) 458-6951 with any questions.