Interpretation ID: nht93-3.2

DATE: April 14, 1993

FROM: Lanny Kness -- Coach Design Engineer, Chance Coach, Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Re: Interpretation of S5.1 and S5.3.3 of FMVSS 101

ATTACHMT: Attached to letter dated 7/7/93 from John Womack to Larry Kness (A41; Std. 101; Std. 108)

TEXT:

Chance Coach is a manufacturer of transit buses, and we are soliciting a written interpretation of two parts of FMVSS 101.

First, S5.1 divides specific motor vehicle controls into three categories: hand-operated controls, foot-operated controls, and displays. If a specific control is furnished, then is it required to be operated per the category's operation? For example: the turn signal control would be hand-operated, the service brake would be foot-operated and the highbeam control could be either hand- or foot-operated. Or should S5.1 be interpreted to mean: if a control is furnished and it is operated in this manner (hand- or foot-), then the following sections of S5.2 and S5.3 apply?

Currently, the turn signal controls of transit buses are mounted to the floor. This position has been used in the transit bus industry since FTA (then UMTA) issued the BASELINE ADVANCED DESIGN TRANSIT COACH SPECIFICATION (referred to as the "White Book"). As stated in the White Book, the turn signals are to be foot-operated momentary contact switches. Do foot-operated turn signals meet S5.1 of FMVSS 101?

A second interpretation is required on S5.3.3 of FMVSS 101. In a transit bus, the furnished controls are located on the dash, and they are illuminated by back lighting their identification. A dimmer switch provides illumination of the identifications over a continuous range. Typically, the windshield wiper/washer controls are provided by a vendor, and they are also installed on the dash. The windshield wiper/washer identifications are located on the control knobs, and they are not backlit. At night, the control knob's identifications are barely discernible from the indirect lighting coming from the other identifications and displays, and very discernible by turning the overhead driver's controlled light on. Does this comply with S5.3.3 of FMVSS 101?

Please contact me at (316) 941-1614, if additional information is needed.

Enclosure

Department of Transportation Urban Mass Transportation Administration BASELINE ADVANCED DESIGN TRANSIT COACH SPECIFICATIONS A Guideline Procurement Document for New 35- and 40-Foot Coach Designs November 1978 (pages II-35 through II-37) (TEXT OMITTED)