Interpretation ID: nht68-1.43

DATE: 06/21/68

FROM: ROBERT M. O'MAHONEY -- NHTSA; CONCURRENCE BY GEORGE C. NIELD

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letter of June 4, 1968.

In your letter you refer to (1) an earlier letter dated November 8, 1967, requesting confirmation of your understanding of the application of the motor vehicle safety standards to recreational vehicles; and (2) a Petition for Reconsideration of the Chassis-cab regulation filed March 19, 1968.

With regard to your letter of November 8, as you know from conversations with members of the staff of the Motor Vehicle Safety Performance Service and the Chief Counsel's Office this letter was misplaced. By letter of May 8, you were good enough to send a copy of the letter of November 8, noting that of the eleven questions asked two have not been clarified by some action taken by the Federal Highway Administration. The unanswered questions are quoted and answered below:

Question --- 3. "The inside mirror need not have the field of view prescribed by Paragraph S3.1.1 of Standard No. 111 (even to the point of providing no view of the road behind a truck camper if the camper mounted on the truck obstructs the driver's vision) provided an outside mirror is installed on the passenger's side of the truck cab, as required by Paragraph S3.2.2."

Answer -- You are correct in your understanding of Standard No. 111. Subparagraph S3.2.2 of Standard No. 111 specifies that if the inside mirror required by S3.1 does not meet the field of view requirements of S3.1.1, an outside mirror of substantially unit magnification shall be installed on the passenger's side.

Question --- 10. "Everything said above concerning truck campers applies equally to truck caps, which are enclosures (roof, sidewalls and ends but no floor and usually no built in equipment) mounted on a pick-up truck.'

Answer --- Truck caps which you describe are considered to be in the same category as slide-in campers and are items of motor vehicle equipment for use in motor vehicles. As such truck caps must meet the requirements of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses, and Motorcycles.

With regard to your Petition for Reconsideration filed March 19, 1968, you note in a letter of May 13, 1968 that three matters raised in the Petition are still unanswered and further action is required. The problems you raise, as you know, are complex. The entire problem of the applicability of the standards to vehicles produced in the multi-stage is still under consideration.