Adrian Burrows, Homologation Engineer
Daewoo Motor Company
Worthing Technical Centre
Downlands Business Park
Lyons Way, Upper Brighton Road
Worthing, United Kingdom, BN149LA

Dear Mr. Burrows:

Thank you for your letter requesting an interpretation of the requirements of two of our safety standards. This letter responds to your questions concerning Standard No. 201, Occupant

Protection in Interior Impact and Standard No. 205, Glazing Materials. I regret the delay in this response.

Your request regards the installation of glass mirrors on passenger side sun visors. You note that Standard 201 does not address the presence of mirrors on sun visors but that S3.4 of the Standard contains general requirements for sun visors. You ask if S3.4 requires the exposed edges of any mirror attached to a sun visor to meet the radii requirements of S3.4.2 or be covered by energy absorbing material pursuant to S3.4.1.

The National Highway Traffic Safety Administration has determined that paragraph S3.4.1 of Standard No. 201 does not prohibit the installation by manufacturers of vanity mirrors on sun visors.

Consequently, so long as the mirror does not interfere with the energy-absorbing requirement of S3.4.1, manufacturers are free to incorporate such mirrors into or onto sun visors.

You also ask if the mirror must meet the radii requirements of S3.4.2. S3.4.2 provides that a visor's mounting must "present no material edge radius of less than 0.125 inch that is statically contactable by a spherical 6.5-inch diameter head form." In a letter dated June 19, 1989, from Stephen P. Wood to a Mr. Jack Satkoski of Spectra Enterprises the agency interpreted this requirement to apply to both the visor and its mount. Therefore, your mirror must be installed in a fashion that assures that your visor meets the radii requirements of S3.4.2

Your final question relates to whether a glass mirror attached to a sun visor must meet any glazing requirements. Standard No. 205 specifies performance requirements for glazing material for use in specified locations in motor vehicles, including motor homes. The agency has previously stated that the standard establishes requirements for glazing used in windows and interior partitions in motor vehicles. Glazing used in locations other than windows and interior partitions would not be subject to the requirements of the standard. Therefore, the vanity mirror you propose would not have to meet the requirements of Standard 205.

I hope that this response is helpful. If you have any questions or comments, please contact Mr. Otto Matheke of this office at (202) 366-5263.

Sincerely,
John Womack
Acting Chief Counsel
ref:201
d.7/3/97