DATE: 11/26/73


TO: Paul R. Hodgson


TEXT: This is in reply to your letter of October 26, 1973, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 111, Paragraph S3.2.1.2 (Mounting).

Paragraph S3.2.1.2 requires, in part, that the outside mirror on the driver's side be capable of adjustment from the driver's seated position. The purpose of this requirement is to ensure that any necessary adjustment of the mirror can be readily accomplished without affecting the continued safe operation of the vehicle in motion. If for some reason the position of the outside mirror were altered so as to obstruct the clear view of the driver to the rear, he would be compelled to leave the highway and remove himself from the vehicle in order to make an adjustment. This possibility defeats one of the purposes of paragraph S3.2.1.2.

Paragraph S3.2.1.2 also provides that the mirror shall not be obscured by the unwiped portion of the windshield. As you stated in your letter, the curvature of the Traveco windshield will not afford an unobscured view of the mirror in that the mirror only retains about 80% of its visibility in the rain and snow. Visibility of 80% does not satisfy the requirements of Standard No. 111.

In summary, the mounting you have suggested for rearview mirrors on the Traveco motor homes is not in conformity with the requirements set out in Paragraph S3.2.1.2 of Standard No. 111. However, pursuant to section 108 (b) (1) of the Vehicle Safety Act, the nonconforming mirrors you have described may be installed if the installation is accomplished after the first purchase of the vehicle for purposes other than resale. You should also be

2 aware that a revision of the standard is presently under consideration which may have an effect on the future compliance of the mirrors.

We appreciate your inquiry.

Yours Truly,



October 26, 1973

Dr. James B. Gregory, Administrator National Highway Traffic Safety Administration

We are writing for an interpretation of the Federal Motor Vehicle Safety Standard No. 111, Section S3.2.1.2 (Mounting, which states: "The mounting shall provide a staole support for the mirror and neither the mirror nor the mounting shall protrude further than the widest part of the vehicle body, except to the extent necessary to produce a field of view meeting or exceeding the requirements of S3.2.1.1. The mirror shall not be obscured by the unwiped portion of the windshield, and shall be adjustable from the driver's seated position. The mirror and mounting shall be free of sharp points or edges that could contribute to pedestrain injury. (32 F.R. 5495 -- April 4, 1967))".

Marion W. Loveless, 1150 South Joplin, Tulsa, Oklahoma, manufacturers rear view mirrors for mobile homes. Traveco Corp. manufacturers mobile homes with wrap around front windshields. Traveco likes Marion's mirrors and would like very much to have them installed on their mobile homes as standard equipment. Traveco wants to be assured that these mirrors are in compliance with Federal Motor Vehicle Safety Standard No. 111.

Marion owns a Traveco mobile home and designed these mirrors for his own use. The most important feature of these mirrors, is: You can see both without taking your eyes off the road, even for an instant. The mirrors are mounted and adjusted in such a manner that a clear and full view to the rear is provided

2 regardless of the height of the individual driving or the place (forward or back) in which the seat is placed (to adjust for leg length. There are no blind spots since you can look over the top of the mirror rather than around it.

We have enclosed pictures for your assistance in visualizing the appearance, location, and effectiveness of these mirrors. Picture #1 gives you the location on the vehicle and the way it is mounted. Picture #2 gives you a view of the left mounted mirror from the driver's eye position. The doors are 10 x 12 feet and the mirror is approximately 100 feet from the doors. Please note that, looking directly at the mirror, one can still see the area in front of the vehicle. Picture #3 is a view from the driver's eye position looking straight down the road. Please note that one can, at the same time, see clearly the rear view from the mirror. Picture #4 shows a view from the driver's eye position. It clearly shows another mobile home in the rear view mirror (left). Picture #5 shows the view, from the driver's eye position, of the right rear view mirror. This clearly shows that the mirror is located in a position where the passenger cannot obstruct the view of the mirror. Picture #6 shows the mirror with the windshield wiper in its furthest left position in relation to the left mirror.

Although the mirror cannot be adjusted from the driver's position, it is mounted and adjusted, when installed, so that it is effective from all positions of the driver in the seat and his height. Marion has driven his for 2 years and never adjusted it since installation. Although the mirror is not within the windshield wiper area, experience has shown its location is such that, driving in the rain and with road dirt and oil, the mirror still retains better than 80% visibility. This is due to the fact the windshield curves and the wind coming around the curve blows the rain, dirt, snow, etc. off the glass through which you look to see the mirror. These mirrors were designed specifically for Traveco and those other mobile homes having a wrap around windshield and a small post. There is a defroster blower mounted inside the windshield which prevents

3 frost, ice, and snow from obstructing a view of the mirror.

We respectfully request an interpretation that the mirrors described above are in full and adequate compliance with Standard No. 111. Your prompt response will be appreciated.

Paul K. Hodgson Attorney for Marion W. Loveless

I have read the above and foregoing request for interpretation and the facts stated therein are true and correct to the best of my knowledge and belief.

Marion W. Loveless

cc: Bud K. Smith, Traveco Corp. Charles Kaehn