Interpretation ID: 1983-1.42

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ichikoh Industries Ltd. -- F. Takata, Manager, Technical Research and Homologation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. F. Takata

This is in response to your letter of March 10, 1983, to Marx Elliot of this agency, In that letter, you requested our view as to whether a mirror label printed by a "screen printing process" would comply with section 5.4.2 of FMVSS 111. The screen printing process involves painting the required warning label on the reverse surface of the mirror in such a way that the warning can be read from the front of the mirror.

Section 5.4.2 of FMVSS 111 provides that certain convex mirrors must have "indelibly etched" on the lower edge of the mirror's reflective surface the warning "Objects in Mirror Are Closer than They Appear." Your screen printing process uses a painting process to place the required lettering on a mirror. Since the process does not involve etching, mirrors having a warning placed on them by that process would not now comply with FMVSS 111.

You should be aware, however, that Toyota Motor Corporation has petitioned this agency to permit processes other than etching to be used to place the FMVSS 111 warning on mirrors. We expect to respond to the Toyota petition in the very near future. Should the agency grant the Toyota petition, it could result in an amendment to the Standard permitting the process described in your letter.

Sincerely, Frank Berndt Chief Counsel

Mr. W. Mark Elliot Rulemaking Program Manager Lighting & Visibility. NHTSA

Re: Interpretation of FMVSS No. 111

Dear Mr. Mark Elliot,

First of all, we thank you very much for your kindly reply on headlamp regulation addressed to our Mr. Aihara. Your informations are very useful for us, thank you again.

We also produce the rear view mirrors for motor vehicle. We would like to ask you the interpretation of FMVSS no. 111, Section 5.4.2.. Section 5.4.2. is defined as follows:

S5.4.2 Each convex mirror shall have indelibly etched on the lower edge of the mirror's reflective surface in letters not less than 3/16 inch or no more than 1/4 inch high, the words "Objects in Mirror Are Closer Than They Appear".

The words "OBJECTS IN MIRROR CLOSER THAN THEY APPEAR" on the sample mirror enclosed this letter was printed by screen printing process as shown in the attached sheets.

Questions: May we understand that marking method of enclosed sample complies with requirements of FMVSS No. 111, Section 5.4.2?

And if your have any comments on enclosed sample, please inform us. We await your early reply.

Very Truly yours.

F. Takata, Manager Technical Research & Homologation Enclosures