Interpretation ID: aiam3540
Sure-View
Inc.
1337 N. Meridan Street
Wichita
KA 67203;
Dear Mr. Urban: This responds to your letter of February 8, 1982, concerning complianc with Federal Motor Vehicle Safety Standards, in particular compliance with Safety Standard No. 111, *Rearview Mirrors*.; You are correct that section 102(2) of the National Traffic and Moto Vehicle Safety Act (15 U.S.C. 1392(2)) defines, in part, a motor vehicle safety standard as 'a minimum standard for motor vehicle performance....' Thus, each of the agency's safety standards sets a minimum level of performance which must be met by every manufacturer. Manufacturers are free to utilize designs that exceeds the minimum level of performance set by a standard as long as their products still comply with the standard. Thus, in the case of schoolbus rearview mirrors, a manufacturer must at least comply with the requirements of section 9.1 of Standard No. 111 regarding mirror size, and may voluntarily provide a mirror of a larger size. As explained in the enclosed letter, the Vehicle Safety Act authorizes the agency to regulate aspect of design, such as mirror size.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel