Denial of Petition for Rulemaking Federal Motor Vehicle Safety Standard No. 105

Résumé

This notice denies a petition for rulemaking by Volkswagen of America, Inc. (VW) to amend Standard No. 105 by reducing the required height for lettering on antilock brake failure indicator lights. VW wants the reduction to facilitate its efforts to develop a single indicator light design that complies with both U.S. and Canadian requirements. Standard 105 provides that if a separate indicator light is provided for antilock brake failure, the indicator must bear one of the following: ``Antilock,'' ``Anti-lock'' or ``ABS.'' Canada requires use of the ISO brake failure symbol. VW's single design would consist of the letters ``ABS'' placed inside the ISO symbol. A letter size reduction would enable VW to avoid having to use what it regards as an overly large ISO symbol. NHTSA is denying this petition for two reasons. First, NHTSA believes that reducing the minimum letter height would make it impossible for many drivers, particularly elderly ones, to read the words and thus discern when there is a brake system failure. Second, the agency is not convinced that the international symbol, by itself, is sufficiently recognizable to be understood as an indication of brake failure by persons u