Interpretation ID: aiam4021
Sales Manager
OEM Division
Velvac
Inc.
2900 South 160th Street
New Berlin
WI 53151;
Dear Mr. Sandham: Thank you for your letter of May 21, 1985, concerning the vertica adjustment of rearview mirrors for trucks. You asked us to clarify whether the standard requires a mirror both to tilt, as shown in your sketch 'A,' and to move up and down its mounting bracket, as shown in your sketch 'B.' As discussed below, a truck mirror can meet the adjustment requirement by either tilting or by moving up and down its mounting bracket.; The agency has not specified the means used to provide a vertica adjustment. We would consider a mirror which tilts, as shown in your sketch 'B,' as meeting the adjustment requirement. You should know that the agency has interpreted this vertical adjustment requirement for trucks to mean that adjustment with tools is allowed. The use of tools is justified because trucks and buses are generally driven for longer periods of time by the same driver and thus the mirror does not have to be continually adjusted.; Please note that S6.1(a) of Standard No. 111 also permits trucks with GVWR of 10,000 pounds or less to be equipped with rearview mirrors which meet the performance requirements for passenger cars in section S5, instead of the requirements for trucks in S6.1(b), S7, or S8. If the passenger car specifications are chosen, the driver must be able to adjust the inside and outside rearview mirrors in both vertical and horizontal directions by tilting them. The agency has not permitted the use of tools for adjusting passenger car mirrors, since passenger cars are often driven by different drivers who will need to quickly and easily adjust their mirrors. A mirror mounted on a universal ball socket joint, for example, meets this requirement. In this situation, the vertical tilting adjustment shown in your sketch 'A' would appear to comply as long as that mirror could also be adjusted horizontally by tilting. The vertical sliding adjustment shown in sketch 'B' apparently would not meet this requirement because it appears to require the use of tools to make the adjustment.; A copy of the current version of Standard No. 111 is enclosed. I hop this information is helpful to you.; Sincerely, Erika Z. Jones, Chief Counsel