Interpretation ID: 77-4.49

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Robert D. Scifres

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of October 27, 1977, asking whether the use of two rearview mirrors in one mounting is permitted if one of the mirrors fails to meet Federal requirements.

Safety Standard No. 111, Rearview Mirrors (49 CFR 571.111), requires each passenger car to have an outside rearview mirror of unit magnification (plane mirror) on the driver's side of the vehicle. Paragraph S4.2.1 of the standard specifies the field of view that must be provided by this outside mirror. Provided the vehicle is equipped with one mirror that meets the requirements of paragraph S4.2.1, the use of additional, non-complying, mirrors is not precluded by the standard, even if the mirrors are in the same mounting with the complying mirror.

Please contact us if you have any further questions.

Sincerely,

ATTACH.

October 27, 1977

TO: U.S. Department of Transportation -- National Highway Traffic Safety Administration

FROM: Robert D. Scifres

SUBJECT: Request for interpretation - Motor Vehicle Safety Standard No. 111, S3.2.1.1

As can be seen in the attached drawing(Exhibit I), this outside rearview mirror for passenger cars incorporates the use of two mirrors located in one assembly. One mirror(A) would conform in all respects to the current standards. The second mirror(B) would conform to all standards except as it relates to the field of vision. In itself the height would not provide the required reflected field of vision, but in conjunction with mirror (A) would provide an expanded field of vision to the extent the "blind spot" would be eliminated. Each mirror is adjustable both horizontally and vertically, allowing the driver to adjust each to give him the maximum reflection.

While the standards do not specifically nor indirectly state a single faced mirror only will be allowed; and although paragraph (1) of 32 F.R. 2413, dated February 3, 1967 relates to a "supplemental" mirror in addition to the inside and outside mirrors; and subsequent revisions do not change the above, I strongly feel an interpretation is in order.

My request comes about because of a very near accident involving me when I started to change lanes on a high speed highway. After checking both inside and outside rearview mirrors, I started to pull into the next lane to my left. Only because the driver of the vehicle behind me was alert prevented a serious accident. I have discussed this situation with about one hundred fifty of my acquaintences and almost all have experienced the same thing in one degree or another with several actually having an accident and three involved in rear end collisions because they had turned their head to make sure about the blind spot only to ram the rear of the cars in front of them.

In view of the standards as written, I feel an interpretation should be given and I shall appreciate an early response to this request

(Graphics omitted)

EXHIBIT I

Fig 1