Interpretation ID: 1984-2.5

TYPE: INTERPRETATION-NHTSA

DATE: 06/01/84

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Intec -- Christopher Moore

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Christopher Moore Intec 23132 La Cadena Languna Hills, California 92653

This responds to your April 24, 1984 letter regarding the installation of a closed circuit television viewing system in new vehicles, as an alternative to rearview mirror systems. The television system provides a view of the area behind the vehicle from a monitor screen placed on or near the dash.

As you note in your letter, Federal Motor Vehicle Safety Standard 111 specifies the use of rearview mirrors to provide improved rearward and side visibility in new motor vehicles. No provision is made for alternative means of compliance such as closed circuit television systems, so such alternative systems are not authorized. However, the closed circuit system could be used as a supplement to a mirror system which meets the requirements of Standard 111.

The only options available to a vehicle manufacturer seeking to use a closed circuit system as a replacement for the required mirror system would be to file a petition to amend the standard or a petition for an exemption from the standard. Requirements applicable to these petitions are set forth in Title 49 of the Code af Federal Regulations, Parts 552 and 555, respectively. These petitions are only granted in the limited circumstances set forth in those regulations.

If you have further questions on this matter, please contact us.

Sincerely,

Frank Berndt Chief Counsel

April 24, 1984

National Highway Traffic Safety Administration Office of the Chief Counsel 400 Seventh Street. S.W. Washington. D.C. 20590 Attention: Mr. Frank A. Berndt, Chief Counsel

Dear Mr. Berndt:

We are the manufacturers of the INTEC "Car Vision" System, a closed circuit television system for vehicular applications. The system is used extensively in the recreational vehicle industry, on refuse and construction equipment and various other commerical vehicles.

Recently, we have had an inquiry from a foreign auto manufacturer via Chrysler Corporation asking about the system for automobiles. The company wishes to replace the existing mirrors with CCTV rearview system but was not familiar with the applicable laws.

After discussing the situation with Mr. Michael Finkelstein, the Associate Administrator for Research and Development and his associate Mr. Robert Henderson, they suggested we talk to your office. Our question is to what extent can a CCTV system replace or enhance the rearview mirrors on an Automobile? We know the current NHTSA Standard No. 111 specifies requirements for rearview mirrors, but no mention of alternatives is provided. Would a CCTV system be a possible replacement?

Enclosed is our sales brochure which outlines the system's technical specifications. We are recommending to Chrysler that a chip camera be substituted for the standard tube model. Chip cameras are not subject to tube burn and are durable enough for vehicular applications.

After you have had a chance to review our literature. I look forward to discussing further the system and any comments and suggestions regarding the law.

Thank you in advance for your time.

Sincerely,

INTEC

Christopher Moore Enclosures Sales CM/gw Attachment --

INTEC CAR VISION

"A must to ensure safety on any large vehicle"

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INTEC'S Car Vision can prevent accidents and ensure safety.

INTEC'S Car Vision can prevent traffic accidents by providing the driver in a large vehicle to see backward clearly when changing lanes, backing-up or when towing any other vehicle. With the aid of Intec's Car Vision, the diver can confirm that the tow hitch is in place and that the vehicle he is towing is alright. The field of view of the Car Vision is from directly downward to the rear bumper to outwards 7 times the height of the installed camera. See diagram with field of view height and width.

Attractive and Compact Monitor with distance grid on screen.

The TV Monitor installed in the divers section is attractive and compact in design. The Monitor can be surface mounted or recessed into the instrument panel. The Monitor has 2 modes brightness switch, one for bright sunshine and the other for night usage.

Shock-proof, vibration-proof and weather-proof construction.

The camera and monitor of INTEC'S Car Vision can withstand locks of 4.4 G's. The Camera does not resonate with any kind of vibration emitted by the vehicle. The Camera is completely weatherproof and can be used on tractors, road rollers and just about any self-propelled outdoor equipment with divers cabs or canopies to cover the monitor.

It serves as another eye for the driver.

On many occasions the diver must watch the situation in the rear, including the objects in a blind spot even when driving forward. For example, a tractor diver must watch what is ahead of him and also his tillage performance in the rear. The INTEC'S Car Vision permits him to see directly behind the vehicle and a lane to each side.

Ultra wide-angle lens yield remarkable wide view.

The ultra wide-angle lens of the Car Vision camera has a local length of only 6.5mm. Its field extends from directly below the lens downward to about 15m away from it horizontally. Because of this unique feature, the Car Vision can be used not only on vehicles but also on sea going vessels and aircrafts. Waterproofing permits all weather outdoor use of TV Camera.

The TV Camera has an airtight, waterproof, all-weather type case. It is extremely suitable as an outdoor-operated camera.

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