ID: nht89-2.90

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: BRADLEY J. BAKER -- PRESIDENT CLASSIC MANUFACTURING, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 10/21/88 FROM BRADLEY J. BAKER -- CLASSIC MANUFACTURING TO TAYLOR VINSON -- NHTSA; OCC 2717

TEXT: Dear Mr. Baker:

This is in reply to your letter to Taylor Vinson of this Office, with reference to a product your company manufactures, a "car dolly used to tow a vehicle behind motor homes." You question whether the dolly is a motor vehicle, and if so, whether identifi cation lamps are necessary for it. I regret the delay in responding.

The car dolly appears to be a vehicle drawn by mechanical power manufactured primarily for use on the public roads, and thus a "motor vehicle" subject to the jurisdiction of this agency. Specifically, it would be a "trailer", since it is a motor vehicle without motive power, designed for carrying property and for being drawn by another motor vehicle. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, requires identification lamps on all trailers whose o verall width is 80 inches or more. Therefore, if the overall width of your dolly is less than 80 inches, it need not be equipped with identification lamps.

Sincerely,

ID: nht89-2.99

TYPE: INTERPRETATION-NHTSA

DATE: 09/14/89

FROM: S. WATANABE -- MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC COMPANY

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL U.S. DOT, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/89 FROM STEPHEN P. WOOD -- NHTSA TO JOHN K. MOODY -- MOODY AND MOODY ENTERPRISES; REDBOOK A34; STANDARD 108; LETTER DATED 08/30/89 FROM JOHN K. MOODY -- MOODY AND MOODY ENTERPRISES TO TAYLOR VINSON -- NHTSA; OCC 3 905

TEXT: Dear Sir,

We are now developing a Head Lamp equipped with VHAD, whose structure is shown in the attached drawing. Please give us the advice to the following questions about this Head Lamp.

1) Does a VHAD without a function which compensates the deviation of floor slope satisfy FMVSS No. 108 S7.7.5.2.(a).(1).(V)?

2) This Head Lamp is designed to be aimed vertically by means of observing only one spirit level placed on the movable reflector, as shown in the drawing. Does this structure of VHAD satisfy FMVSS No. 108 S7.7.5.2.(a).(1).(V)?

Any information that might be of our interest when designing the Head Lamp with VHAD, as well as the answers to the above questions, would be highly appreciated.

Yours faithfully,

ID: 7034

Ms. Eileen Mathews
Industry Manager, Hose and Tubing
General Electric Company
2 Summit Park Dr.
Suite 410
Independence, OH 44131

Dear Ms. Mathews:

This concerns your letter to the Federal Highway Administration (FHWA) asking about FHWA's regulation 393.45 (49 CFR 393.45) and NHTSA's Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. FHWA provided us a copy of its March 6, 1992 response on regulation 393.45. This letter answers your question about Standard 106.

You ask about S7.3.6, 7.3.10 and 7.3.11 of the standard. Those sections set forth performance requirements for limiting the amount a hose may change in length under specified conditions (S7.3.6), for the tensile strength of a hose assembly (S7.3.10), and for the tensile strength of an assembly after immersion in water (S7.3.11). Each of these sections excludes certain items from the requirement.

Your question relates to those exclusions. S7.3.6 excludes coiled nylon tubes for use in assemblies that meet the FHWA requirements of 393.45. S7.3.10 excludes coiled nylon tube assemblies that meet 393.45. S7.3.11 excludes coiled tube assemblies that meet 393.45.

You ask whether those exclusions in S7.3.6, 7.3.10 and 7.3.11 "require compliance with 393.45." The answer is no. Standard 106 does not require tubing to meet 393.45. Instead, compliance with 393.45 is a condition for excluding the item from S7.3.6, 7.3.10 or 7.3.11.

The other condition, relevant for S7.3.6 and 7.3.10, is that the brake hose be coiled nylon tubing. According to your letter, the brake hose (tubing) of your concern would be made from a material other than nylon. Since the second condition would not be satisfied, such hose would not qualify for the S7.3.6 exception, and an assembly made from such hose would not qualify for the 7.3.10 exception, regardless of whether the hose meets regulation 393.45. Thus, S7.3.6 and 7.3.10 would apply to hose and assemblies made from your product, without exception.

S7.3.11 does not specify that the coiled tubing must be nylon to qualify for the exception. While NHTSA intended to specify nylon (see, preamble to rule adopting the exclusion, 39 FR 28436; August 7, 1974), as adopted, S7.3.11 excludes a "coiled tube assembly" that meets regulation 393.45 from its requirements.

I hope this information is helpful. If you have any further questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:106 d:5/11/92

ID: nht73-5.43

DATE: 11/05/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gerald Ahronheim

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your request for a statement of your odometer disclosure obligations under the Motor Vehicle Information and Cost Savings Act, Public Law 92-513.

Under the Act, all transferors must make a "mileage statement" to the transferee. "Transferor" means any person who transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest. This includes a dealer transferring a new or used vehicle. The only exceptions to the requirement are for vehicles over 16,000 pounds gross weight rating, non-self-propelled vehicles, vehicles 25 years old or older, and new vehicles sold by a dealer to another dealer for resale.

The statement must contain (1) the odometer reading, (2) date of transfer, (3) transferor's name and current address, (4) vehicle identification or serial number, make, model, year, body type, last plate number, (5) a statement that actual mileage differs from recorded mileage if such is the case and the transferor knows it, and (6) reference to the Motor Vehicle Information and Cost Savings Act with the statement that incorrect information may result in civil liability under it. An example of an adequate statement and format is enclosed for your information.

The federal government does not print these forms but several commercial printers have prepared Federal disclosure forms for the convenience of dealers. Alternatively, the statement

may be included in the bill of sale, or other transfer document. In any case, it must be completed and signed prior to the transfer. Either the original or carbon copy may go to the transferee. You can see that the transferor must make a statement about actual mileage only if he knows that it differs from recorded mileage. A person like yourself who has no knowledge of odometer accuracy would only state the recorded mileage.

A copy of the Act is also enclosed for your information.

ENCLS.

October 9, 1973

Dear NHTSA

This note is prompted by Sylvia Porter's column which appeared in the Detroit Free Press of Wednesday, October 10 1973 (page 6-C) concerning the 1972 Motor Vehicle Information and Cost Savings Act.

As one who has owned several previous-owned cars and who doesn't anticipate purchasing any new car in the near future, I am concerned about possibly unwittingly violating the 1972 act, of which I was not previously aware. For example, I have sold two cars which I had bought used in the past 13 months, and now am driving a 1951 automobile which may follow its predecessors. How can I guarantee the mileage of these cars? I can't attest to the honesty of the previous owners, and even though both cars were purchased in earlier times I have no way of verifying anything which could have been tampered with. Does the Act protect a seller from unwittingly becoming liable for omissions or commissions of others?

What is the document -- "Disclosure Statement" -- referred to by Ms. Porter? Is this a standard form, an amendment to a bill-of-sale, or anything in a contractual form? Where are these documents to be obtained, and who must complete them? Must one be furnished with every vehicle sale (e.g. motorcycle, bicycle, ORRV) and by any seller (private individual vs. dealer)?

I'd be very grateful for official answers to these questions specifically, as well as for a copy of the Act and any information booklet you may have printed. Thank you very much.

Respectfully,

Gerald Ahronheim

ID: nht76-5.58

DATE: 07/07/76

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Carideng

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your telex of June 18, 1976, requesting information concerning the designation of an agent for service of process and the assignment of a tire identification number.

Section 110(e) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States to designate a permanent resident of the United States as his agent upon whom service of all processes, orders, decisions, and requirements may be made. Such designation should be filed with the Office of Chief Counsel of the National Highway Traffic Safety Administration.

In order for the designation to be effective, it is necessary that the procedural requirements of 49 CFR 551.45 (enclosed) be fulfilled by the submission of the following information:

1. A certification that the designation is valid in form and binding on the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made;

2. The full legal name, principal place of business and mailing address of the manufacturer;

3. Marks, trade names, or other designations of origin of any of the manufacturer's products which do not bear his name;

4. A statement that the designation shall remain in effect until withdrawn or replaced by the manufacturer;

5. A declaration of acceptance duly signed by the agent appointed, which may be an individual, a firm, or a U.S. corporation; and

6. The full legal name and address of the designated agent.

In addition, the designation must be signed by one with authority to appoint the agent; the signer's name and title should be clearly indicated beneath his signature.

Part 574, Tire Identification and Recordkeeping, does not require the designation of an agent for service of process prior to the assignment of a tire identification number. We are, therefore, forwarding your code number. Your tire identification number is T4.

Although you have been assigned an identification number, you are not permitted by Federal law to offer tires for importation into the United States until you have properly designated an agent for service of process. If you decide for any reason not to offer your tires for importation, we request that you notify the agency so that your tire code number can be placed in our inactive file.

If you have any questions concerning these requirements, please do not hesitate to contact me.

SINCERELY,

JUNE 18, 1976

TELEX MESSAGE FOR: U S DEPARTMENT OF TRANSPORTATIONS NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION ATT. E. T. DRIVER DIRECTOR OFFICE OF CRASH AVOIDANCE MOTOR VEHICLE PROGRAMS.

DEAR SIRS,

WE NOW URGENTLY NEED TO HAVE OUR MOTORCYCLE (MOPED) TYRES AGREED FOR SALES IN THE USA. HOWEVER, FROM YOUR LETTER REF. N41-33 DD. MAY 6, 196EEE1976 WE UNDERSTAND THAT TO OBTAIN A TIRE IDENTIFICATION OR NUMBER WE SHOULD HAVE AN AGENT ESTABLISHED IN THE USA, WHILE THIS IS NOT THE CASE AND WE HAVE ONLY A COMMISSION AGENT TRAVELLING 3 OR 4 TIMES A YEAR THROUGH THE USA BUT LIVING IN EUROPE. PLSE LET US HAVE YOUR FURTHER INSTRUCTIONS AND SUGGESTIONS AND AT THE SAME TIME GIVE US AN IDEA OF THE ESTIMATED DELAY THAT IS NECESSARY TO OBTAIN A TIRE IDENTIFICATION NUMBER.

THANK YOU IN ADVANCE FOR YOUR COOPERATION D. PONCELET RUBBERFACTORY CARIDENG LANAKEN - BELGIUM

ID: 17712.drn

Mr. Harold V. Turnquist
Transportation Director
District 625
Saint Paul Public Schools
360 Colborne Street
Saint Paul, MN 55102-3299

Dear Mr. Turnquist:

This responds to your April 7, 1998, letter to Mr. Bob Pollack of the National Highway Traffic Safety Administration (NHTSA's) Region V Office, asking for information whether your department may use 15-passenger vans to transport adults and their children in your Early Childhood and Family Education Program (ECFE). As explained below, we do not consider the ECFE Program to constitute a "school" as that term is used in our statute. Thus, new buses leased to you for transporting ECFE Program participants are not required to be school buses under Federal law.

Your letter explains that the Saint Paul Public Schools Community Education Department operates a parent education program for adult learners called the ECFE Program. The program is described as follows:

Parents and their non school age children, who range in age from a few months to three or four years old, attend programs designed to assist the parent in developing skills necessary for raising their children. Class locations include both storefront locations (leased space) and public school buildings. When ECFE Programs are housed within school buildings there is no connection between the ECFE Program and the school program.

Your letter states that your Department is leasing several 15-passenger vans to transport ECFE Program participants. According to your letter, Minnesota state law does not require school bus transportation for ECFE Program participants.

In a telephone conversation with Dorothy Nakama of my staff, Mr. Mark Vogel of your office stated that the adult participants in the ECFE Program are not high school age, i.e., they are all older than eighteen. Mr. Vogel also stated that the young children transported in the vans are in vehicle safety restraints appropriate for their size and age.

By way of background, NHTSA is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 (copy enclosed) requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "school bus" as any vehicle that is designed for carrying 11 or more persons and which is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125 (copy enclosed). Therefore, large (e.g., 15-passenger) vans that are likely to be used significantly to transport school students are "school buses."

The question raised by your letter, whether the ECFE Program constitutes a "school" is one the agency finds appropriate to resolve case-by-case, focusing on the type of services provided by the organization at issue.

The facts you have provided show that the adult participants in the ECFE Program are older than high school age. Your letter states that the adults attend programs "designed to assist the parent in developing skills necessary for raising their children." For purposes of NHTSA's safety standards, I have concluded that instruction in developing these skills are distinct from the academic instruction associated with a "school," and that therefore, the ECFE Program is not a "school." Accordingly, if a dealer were to sell or lease a new bus (e.g., a 15-passenger van) to the Saint Paul Public Schools Community Education Department for the exclusive use of the ECFE Program, that dealer need not sell or lease a new school bus.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:VSA#571.3
d.4\29\98

ID: nht92-6.10

DATE: June 11, 1992

FROM: Bob Clement -- U.S. House of Representatives

TO: Andrew Card, Jr. -- Secretary, Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 6/30/92 from Frederick H. Grubbe to Bob Clement (A39; Part 571.3)

TEXT:

I have recently been contacted by my constituents throughout the State of Tennessee who are concerned about the impact of a Federal law regarding the transportation of school children.

According to my constituents, the Federal law permits school officials to use vans equipped to transport up to 10 passengers; however, they are prevented from transporting school children in vans equipped to transport 11 or more passengers. It is my understanding that the school officials would like to use these vans to transport children participating in after-school athletic events.

I have attached a sample constituent letter for your review. I would greatly appreciate knowing if the regulations provide any relief for the school districts in this situation. If not, I would like to know if the National Transportation Safety Board or the Department of Transportation have considered revising the regulations on this matter.

If you need additional information or have any questions, please feel free to contact me or Jay Hansen of my staff at (202)225-4311.

Thank you in advance for any assistance you may be able to provide.

Attachment

Letter dated 5/29/92 from James C. Campbell, Athletic Director, Maryville High School, Maryville, Tennessee. Text of letter:

Dear Legislator:

Recently throughout our State much concern has mounted in regard to recent memos from Mr. Ernest Farmer, Director of Pupil Transportation, Tennessee State Department of Education. These memos have directed attention to an early 1970's federal law pertaining to use of vehicles with a capacity of eleven (11) or more.

Over the years, many schools throughout the State have made use of 12 and 15 passenger vans to transport athletic teams and other school groups to and from school-related events. These vans are NOT used for "pick-up" and "drops" on public roadways. Now, many systems have either had to park their vans or they are under a deadline to do so. This action already has or will create a tremendous financial burden on schools already strapped with financial hardships due to budget cuts. We fear the ultimate result will be the elimination of certain athletic teams and other school functions simply due to the enormous expense involved in renting buses on a daily basis. Also, another problem is that of finding buses available at the time of day needed.

At Maryville High School we have suspended use of two vans that were used for a variety of student activities. Replacing these resources means hiring school buses which we know will increase costs. Due to this change we are considering eliminating some valuable parts of our student activity programs.

We desperately need your help in seeing that this law is amended or changed in order to permit the use of these vehicles. To ensure that vans are maintained in a safe condition, they can be required to have the same inspection as that imposed on regular school buses.

We have real problems with, and do not understand the rationale, of a law that states we can legally use a van equipped to transport 10 passengers but we cannot use a van equipped to transport 11, 12, or 15 passengers. We appreciate your concern in this matter and desperately need your support.

ID: 1979y

To: DOERNBERG, David G.
From: ROBERTSON, Marcia
Subject: aia Date: 09/15/89
Reply by: 00/00/00
----------------------------------------------------------------------------
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Mr. William G. Kinstler American Flatlight Company 414 Richard Road Rockledge, FL 32955

Dear Mr. Kinstler:

This is in reply to your letter with respect to a portable illuminated device, called the "Flatlight." You have asked for our review of the advertising brochure that you enclosed, and for copies of any regulations regarding this product. I regret the delay in responding.

Your brochure indicates that Flatlight is intended for mounting on the door of a motor vehicle, and connects to the battery by a wire. As shown, it contains a corporate logo, which "emits a pleasant glow." The purpose is to readily identify the presence of "Real Estate Companies and other Sales Agents who need to meet clients at night."

This agency establishes the Federal motor vehicle safety standards that apply to new motor vehicles and motor vehicle equipment. It also establishes regulations pertaining to safety-related defects in motor vehicles and motor vehicle equipment. As Flatlight is advertised almost exclusively for motor vehicle applications (we note a single remark that it can be used for store and window fronts), it is "motor vehicle equipment" subject to the jurisdiction of this agency.

The only Federal motor vehicle safety standard that applies to portable lighting equipment applies only to warning triangles without self-contained energy sources, and thus does not cover the rectangular Flatlight. The Federal lighting standard on lamps, reflective devices, and associated equipment, permits Flatlight to be installed as original equipment (e.g., installed by the dealer on a new vehicle before its delivery to its first purchaser), if it does not impair the effectiveness of lighting equipment required by the standard. It seems unlikely that the "glow" of a door mounted Flatlight would impair the effectiveness of the required side marker lamps and reflectors; indeed the device might serve more readily to identify the vehicle at night.

We surmise, however, that Flatlight is intended for the aftermarket and for installation on vehicles in use. It appears easily transferable from one vehicle to another. Installation of aftermarket motor vehicle equipment is generally permissible under Federal law. However, the installation is prohibited if it is installed by a motor vehicle manufacturer, distributor, dealer or repair business and if such installation renders inoperative, either wholly or partially, equipment installed in accordance with a Federal motor vehicle safety standard. Installation of Flatlight does not appear to present this possibility.

Even though Flatlight is not prohibited under Federal law, you must still determine whether it is permissible under the laws of any State in which it may be installed. We are unable to advise you on State law, but recommend that you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203.

Finally, because Flatlight is "motor vehicle equipment" you, as its manufacturer, must notify purchasers and provide a remedy upon any determination by you or this agency that it contains a defect related to motor vehicle safety.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d:8/ll/89

ID: 19187.drn

Larry Schooley, Senior Director
Bancroft School
Hopkins Lane
P.O. Box 20
Haddonfield, NJ 08033-0018

Dear Mr. Schooley:

This responds to your request for an "exemption" from a statute that you describe as being "passed as of July 31, 1998, requiring all students to be transported in a school bus." Your letter describes the Bancroft School as a "private school for the handicapped." We cannot grant your exemption since there is no Federal statute such as the one you describe, requiring school bus transportation for students. The National Highway Traffic Safety Administration has no authority to do so, and does not require any school to transport students by school bus only. Transportation for students in your school would be determined by State law.

By way of background, NHTSA is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a 15-person van that is likely to be used significantly to transport students is a "school bus."

In general, NHTSA's safety standards directly regulate the manufacture and sale of new motor vehicles, not their use. Each State has the authority to set its own standards regarding the use of motor vehicles, including school buses.

Dorothy Nakama of my staff has discussed your letter with Ms. Linda Wells, Director, Office of Pupil Transportation, New Jersey Department of Education. Ms. Wells indicated that the issue raised in your letter may concern a matter falling within New Jersey's jurisdiction. Therefore, please address your concerns to:

Ms. Linda Wells, Director
Office of Pupil Transportation
New Jersey Department of Education
P. O. Box 500
Trenton, NJ 08625-0500

In closing, we wish to emphasize that school buses are one of the safest forms of transportation in this country, and that we therefore strongly recommend that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. Further, using 15-person vans that do not meet NHTSA's school bus standards to transport students could result in increased liability in the event of a crash. Since such liability would be determined by State law, you may wish to consult with your attorney and insurance carrier for advice on this issue.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
cc: Ms. Linda Wells, Director
Office of Pupil Transportation
New Jersey Department of Transportation
P.O. Box 500
Trenton, NJ 08625-0500
ref:571#VSA
d.2/26/99

ID: 77-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your January 17, 1977, letter concerning the requirements of Safety Standard No. 111, Rearview Mirrors, for passenger cars. You requested confirmation of your interpretation that the standard specifies no requirements for outside rearview mirrors on the passenger's side of the vehicle when the inside rearview mirror meets the field of view performance requirements of paragraph S5.1.1 of the standard.

Your interpretation is correct. If the inside rearview mirror of a passenger car meets the specified performance requirements, the vehicle is not required to be equipped with an outside rearview mirror on the passenger's side. However, a manufacturer is free to equip its vehicles with outside right-hand mirrors, either plane or convex, if he choses.

You should note that each passenger car whose inside rearview mirror does not meet the field of view performance requirements of paragraph S5.1.1 must have an outside rearview mirror of unit magnification installed on the passenger's side of the vehicle.

SINCERELY,

BMW OF NORTH AMERICA, INC.

January 17, 1977

Frank A. Berndt, Esq. Acting Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

Federal Motor Vehicle Safety Standard, FMVSS 111, Paragraph 5.3, states that "each passenger car whose inside rear view mirror does not meet the field of view requirements of S 5.1.1, shall have an outside rear view mirror of unit magnification installed on the passenger side . . . " (emphasis added).

In Paragraph S 5.3, the emphasis is placed on the inside rear view mirror, which does not meet the field of view requirements of S 5.1.1.

It is BMW's understanding that the outside rear view mirror on the passenger side, whether of unit or non-unit magnification, does not fall within the jurisdiction of FMVSS 111, when the vehicle's inside rear view mirror meets the field of view requirements of S 5.1.1.

Your confirmation in writing of this understanding would be appreciated.

Karl-Heinz Ziwica Manager, Safety Engineering