Interpretation ID: aiam2517
Chief Product Engineer
Harman International Industries
Inc.
P.O. Box 329
Bolivar
Tennessee 38008;
Dear Mr. Hadley: This responds to your February 2, 1977, request for approval of Harma Industries procedure for measuring the average reflectance value of its 'Nite-Ban' rearview mirror. You describe the 'Nite-Ban' as a mirror glass having a band of low reflectance horizontal to the horizon and centered between the top and bottom of the glass. You request confirmation that the 'Nite-Ban' mirror conforms to the requirements of Standard No. 111, *Rearview Mirrors*.; Paragraph S11 of Standard No. 111, 49 CFR 571.111, specifies that th *average* reflectance value of any mirror required by the standard shall be at least 35 percent, determined in accordance with SAE Recommended Practice J964a. If the average reflectance value of the reflective surface of a 'Nite-Ban' mirror is at least 35 percent, the mirror is acceptable under Standard No. 111. However, it is the responsibility of the manufacturer to determine if an item of motor vehicle equipment complies with applicable safety standards. The agency cannot grant prior approval.; Further, the agency cannot approve a manufacturer's test procedures i advance. Therefore, we cannot confirm that your proposed procedure for measuring the average reflectance value of 'Nite-Ban' mirrors is an acceptable procedure. It is the manufacturer's responsibility to exercise sound engineering judgement in determining that its vehicle meet the performance levels prescribed in the safety standards.; Sincerely, Frank Berndt, Acting Chief Counsel