Interpretation ID: aiam3829
Research and Development Laboratories
U.S. Postal Service
Rockville
MD 20852-8101;
Dear Mr. Premack: This responds to your March 7, 1984 letter to Roger Fairchild of thi office regarding Federal Motor Vehicle Safety Standard (FMVSS) 111, *Rearview Mirrors*. In particular, you asked whether the covering of the rear and rear-side windows on Postal Service Vehicles would be consistent with the requirements of FMVSS 111.; FMVSS 111 (copy enclosed) establishes requirements regarding rearvie mirror systems on new motor vehicles. New Postal Service vehicles would be required to employ one of three optional mirror systems. The first system is a system permitted for use on passenger cars, and includes an inside rearview mirror with a specified field of view and a plane, driver's side exterior mirror also having a specified field of view. The second permissible system is also a passenger car system and is identical to the first system, except that the inside mirror need not provide the specified field of view and an additional passenger side plane or convex rearview mirror must be provided to compensate for the more restricted field of view of the inside mirror. The third system has two plane mirrors of 19.5 square inches reflective surface area each, one mounted on each side of the vehicle.; Based on the materials you provided with your letter, it appears tha Postal Service DJ-5G Models employ the second system described above. In that case, further reduction of the field of view of the inside rearview mirror would not affect compliance with our standard, since an additional passenger side mirror is provided.; If the proposed covering of the rear windows is to be accomplished as modification to vehicles already delivered to the Postal Service, these modifications may not be subject to FMVSS 111 at all. Modifications to vehicles must be consistent with safety standards only to the extent those modification are performed by a vehicle manufacturer, distributor, dealer, or private motor vehicle repair business which knowingly renders inoperative safety equipment installed on the vehicle. See 15 U.S.C. 1397(a)(2)(A). Thus, if the window covering is done by the Postal Service itself, FMVSS requirements are not applicable.; If you have any further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel