Interpretation ID: aiam4215
United States Senate
112 Hart Senate Office Building
Washington
DC 20510;
Dear Senator Cranston: This responds to your letter on behalf of Mr. Raymond Kesler. He aske for this agency's response to a letter from Mr. Robert R. Philips concerning the bi-focal mirror developed by Mr. Kesler. In his letter, Mr. Phillips asked whether an outside rearview mirror, which has both a planar surface of unit magnification and a convex surface, complies with Standard No. 111, *Rearview MIrrors*. I regret the delay in responding to this letter.; As we understand the information supplied by Mr. Phillips, the bi-foca mirror would be installed on the driver's side of motor vehicles to give the driver a wider field of view by combining a convex mirror and a planar mirror as the outside rearview mirror on the driver's side. The convex portion would abut the planar portion and be located to the left of the planar portion. Thus, both normal and wide-angle vision would be provided at the same horizontal viewing level.; By way of background information, this agency does not give approval of vehicles or their equipment. The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), places the responsibility on the manufacturer to ensure that items of motor vehicle equipment, such as rearview mirrors, comply with any applicable requirements. A manufacturer certifies that its equipment complies with all applicable safety standards.; Mr. Phillips asked this agency to confirm his interpretation that thi bi-focal mirror meets the requirements of Standard No. 111 if its planar or unit magnification surface has an area of at least 19.5 square inches, regardless of the existence of the convex portion. The 19.5 square inch requirement is one applicable to multipurpose passenger vehicles, trucks, and buses (other than schoolbuses) with a GVWR of 10,000 pounds or less. Those types of vehicles are required by S6.1 of the standard either to have a set of inside and outside rearview mirrors that comply with the requirements applicable to passenger cars or to have outside mirrors of unit magnification, each with not less than 19.5 square inches of reflective surface, on both sides of the vehicle. If Mr. Phillips' mirror meets that size requirement, is located on a vehicle so as to provide the required view and is adjustable in the required manner, it complies with S6.1.; There are no minimum size requirements for unit magnification outsid rearview mirrors on passenger cars. Mr. Phillips' mirror can be installed on the driver's side of passenger cars if the mirror's unit magnification portion, independently of the convex portion, meets the field of view and mounting requirements specified in S5.2.; In one drawing accompanying Mr. Phillips' letter, there appears to be warning on the planar portion of his bi-focal mirror stating 'Objects Appear Within Markers: Caution.' There is no requirement in Standard No. 111 for such a warning. The agency is concerned that the message conveyed by this warning is unclear and could confuse motorists. The warning ('CAUTION When Vehicle Appears Here') in Mr. Phillips' other drawing seems more easily understood. He might consider providing purchasers with written instructions explaining that the purpose of the message is to warn drivers that the appearance of a vehicle in the convex portion of the mirror means that the vehicle is so close that a lane change would be unsafe.; Unit magnification and convex mirrors on other types of vehicles mus meet the specific performance and location requirements for those types of vehicles, as set out in the standard. Again, please note that a vehicle manufacturer installing a bi-focal mirror on different types of vehicles must ensure that the unit magnification portion of the mirror meets any applicable requirements of the standard independently of the convex portion.; If Mr. Phillips' mirror meets the requirements of Standard No. 111 fo a particular vehicle type, then it may be installed on new vehicles of that type. It may also be installed on used vehicles of that type.; Conversely, if the mirror does not meet those requirements, then it ma not be installed on new vehicles. Further, manufacturers, distributors, dealers and repair businesses would be prohibited from installing it on used vehicles. However, the Act does not establish any limitations on an individual vehicle owner's ability to alter his or her own used vehicle.; Under Federal law, individual vehicle owners can themselves install an product they want on their used vehicles, regardless of whether that product would render inoperative the compliance of the vehicle's rearview mirrors with the performance or location requirements of Standard No. 111.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel