Interpretation ID: nht94-4.96

TYPE: INTERPRETATION-NHTSA

DATE: December 6, 1994

FROM: G. Brandt Taylor -- President, Day-Night Mirrors, Inc.

TO: Chief Council -- NHTSA

TITLE: Reference: Code of Federal Regulation Title 49 Section 571.111 Chapter V Standard 111: Rear-view Mirror Paragraph S11. Mirror Construction

ATTACHMT: ATTACHED TO 2/13/95 LETTER FROM PHILIP R. RECHT TO G. BRANDT TAYLOR (A43; STD. 111)

TEXT: We at Day-Night Mirrors have developed a rear-view mirror that changes reflectivity. Please see figure A. We have a question in regard to the above referenced regulation. Our mirror is a mechanical device that is operated by rotating a shaft. For rem ote actuation an electric motor and worn gear assembly could be used. The regulation requires that electrically actuated mirrors have means to override the electrical actuator in the event of an electric malfunction. Ours could be manually overriden wi th a knob as in figure B. Could this override be removable? Figure C. In particular could the override actuator be supplied by the car manufacturer along with the car keys or with the owners manual for insertion into the mirror and use only in the even t of some electrical failure? Would this removable mechanical actuator be acceptable for west coast mirrors on trailer trucks?

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