Interpretation ID: nht87-1.64

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: George Ziolo

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. George Ziolo 16182 Arena Drive Ramona, CA 92005

Dear Mr. Ziolo:

This letter responds to your inquiry concerning Federal Motor Vehicle Safety Standard No. 111. I apologize for the delay. As I understand your question, you are concerned with a passenger car whose inside rearview mirror apparently does not meet the fiel d-of-view specifications in S5.1 of FMVSS 111 and therefore that must have an outside passenger side mirror in order to comply with the standard. You wish to know whether the need to inscribe the convex mirror in accordance with S5.4.2 is eliminated when the passenger side of the car has both a complying mirror of unit magnification and a convex mirror.

Please understand that the National Highway Traffic Safety Administration (NHTSA) does not approve motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the manufacturer's responsibility to ensure that its vehicle or equipment complies with applicable standards. Therefore, this letter is an opinion based on the facts you provide in your letter.

The answer to your question is "yes." The passenger side of a new car would need an outside convex mirror inscribed in accordance with S5.4.2 only if its inside rearview mirror failed to meet the S5.1.1 field of view specifications, and the manufacturer chose to comply with the requirement of S5.3 for an outside passenger side mirror by installing a convex passenger-side mirror rather than a unit magnification passenger-side mirror. S5.4 provides that the requirements in S5.4.1 - S5.4.3 are applicable t o a convex mirror only if that mirror is used to comply with S5.3. In your example, a mirror of unit magnification is used to comply with S5.3. I should add that the manufacturer would have to ensure that installing the convex mirror does not take the mi rror of unit magnification out of compliance with FMVSS 111.

Please let me know if you have any further questions.

Sincerely, Erika Z. Jones Chief Counsel

GEORGE ZIOLO 16182 ARENA DRIVE RAMONA, CA 92065 619-789-9792

Office of the Chief Counsel US DOT/NHTSA 400 7th St SW Washington, DC 20590

Subj: FMVSS 111

A convex mirror installed in accordance with (IAW) S5.3 must meet S5.4.2 (inscription)

Mirrors installed IAW S6 must meet S6.1(a) or (b); the latter makes no mention of a convex mirror.

I have observed that vehicles falling into the category specified in S6 are sold with mirrors meeting S6.1.(b). However, in addition to mirrors of unit maginification, convex mirrors are also installed but they do not bear the inscription mentioned in S5 .4.2 (bear no inscription).

It therefore appears to me that when a mirror of unit magnification is supplemented by a convex mirror, the latter need not meet the inscription requirement of S5.4.2.

The question therefore arises whether the above would as well apply to vehicles falling into the category of S5 - passenger cars. That is to say, is the need for the inscription (S5.4.2) eliminated when there is installed a mirror of unit magnification in addition to a convex mirror.

Please advise me of your opinion in this matter.

Sincerely,

GEORGE ZIOLO DOT Paperwork Processor