2008 smart fortwo, BMW X5, Audi R8: FMVSS 102 Transmission Shift Position Sequence
January 24, 2009
In my last smart fortwo passion blog, the comments strayed away from the topic at hand (as is the point of the internet) and onto the shift pattern of the US model versus that of the European one. The statement from Bumby was "We didn't get the Euro shifter because the PRND layout is required by US law." EPBrown found an exception to this quickly "We're swimming in cars that use semi-auto gearboxes that use the N/R/+/- shifter. It's on every SMG-equipped BMW." That got me to thinking and then to researching exactly what is required by the NHTSA. And let me tell you now, it's not easy. The NHTSA only lists a "quick reference" guide to searching the Federal Motor Vehicle Safety Standards. In order to access the full text, one needs to go to http://www.gpoaccess.gov/ and search for "49 CFR 571." Obvious, right? Whatever, here it is:
FMVSS Rule 102 beings "Sec.571.102 Standard No. 102; Transmission shift position sequence, starter interlock, and transmission braking effect. S1. Purpose and scope. This standard specifies the requirements for the transmission shift position sequence, a starter interlock, and for a braking effect of automatic transmissions, to reduce the likelihood of shifting errors, to prevent starter engagement by the driver when the transmission is in any drive position, and to provide supplemental braking at speeds below 40 kilometers per hour (25 miles per hour). " That sounds about what I was looking for.
The section that pertains to our question is S3.1.1: (S3.1, of course, being titled Automatic Transmissions.) "Location of transmission shift positions on passenger cars. A neutral position shall be located between forward drive and reverse drive positions." And S184.108.40.206: "Transmission shift levers. If a steering-column mounted transmission shift lever is used, movement from neutral position to forward drive position shall be clockwise. If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position."
Oh, but that only appears to deal with column-mounted shifters, not the nub of a shift lever the 2008 X5 uses, let's try "S3.1.4 Identification of shift positions and of shift position sequence. S220.127.116.11 Except as specified in S18.104.22.168, if the transmission shift position sequence includes a park position, identification of shift positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever any of the following conditions exist: (a) The ignition is in a position where the transmission can be shifted; or (b) the transmission is not in park." That would mean that the BMW's park button is legally acceptable, but still stupid.
But what about the R8 and BMWs with SMG? Well, S22.214.171.124 handles that: "Except as specified in S126.96.36.199, if the transmission shift position sequence does not include a park position, identification of shift positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever the ignition is in a position in which the engine is capable of operation."
The rest of FMVSS 102 isn't nearly as exciting, but that seems to have settled the debate pretty thoroughly: PRND is not required, but N must be between D and R and, if applicable, Park must be labeled (as it is in the X5), and if there is no park (like the R8 and the M3 with DCT), gear position must be labeled and visible to the driver.
Here are quick links to FMVSS 102 and to the entirety of the Code of Federal Regulations Title 49: Transportation.
Mike Magrath, Vehicle Testing Assistant and unqualified legal researcher
Smart and X5 photos by Kurt Niebuhr, R8 photo by Bryan Moody