Interpretation ID: nht94-8.11

DATE: February 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jane L. Dawson -- Specifications Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/2/93 from Jane L. Dawson to Charlie Hott (OCC-9045)

TEXT:

This responds to your questions about a December 2, 1992, rule that amended Standard No. 111, Rear-view mirrors, by establishing field-of-view requirements around school buses (57 FR 57000). The rule amended Standard No. 111 to require a bus driver to be able to see, either directly or through mirrors, certain specified areas in front of and along both sides of school buses. I apologize for the delay in responding.

Your first question asks: Are we required to certify that the mirror system HAS THE ABILITY to be adjusted for viewing of the cylinders by a 25th percentile female or to certify that the mirror system HAS BEEN adjusted?

Under the National Traffic and Motor Vehicle Safety Act, each new vehicle manufacturer must certify that its vehicle complies with the Federal motor vehicle safety standards (FMVSS's). NHTSA evaluates a vehicle's compliance with the safety standards using the test procedures and conditions specified in the FMVSS's. Standard 111 requires that specified areas must be visible when viewed from the eye location of a 25th percentile adult female (S9, S13). The test procedures of S13 state that, when testing a school bus, NHTSA will adjust an adjustable mirror to the eye location of a 25th percentile adult female before the test, in accordance with the manufacturer's recommendations (S13.3). Of course, to comply with Standard 111, the mirror will have to be able to be adjusted to the required location at the time NHTSA tests the vehicle.

Your second question asks: Are the outside rearview mirrors required to view the area straight down from the mirrors and 200 feet rearward?

In an October 21, 1993, telephone conversation with Marvin Shaw of my staff, you explained that you ask whether S9.2 of Standard 111 requires measurement beginning at the ground below the System A mirror (and extending at least 200 feet behind that plane).

The answer is yes, the mirror must provide a view of the area straight down from that mirror and extending 200 feet rearward. Section S9.2 states that each school bus must have two outside rearview mirror systems: A System A driving mirror and a System B convex cross view mirror. The System A mirror on the left side of the bus is required by S9.2(b)(2) to provide a view of "the entire top surface of cylinder M in Figure 2, AND OF THAT AREA OF THE GROUND WHICH EXTENDS REARWARD FROM THE MIRROR SURFACE not less than 60.93 meters (200 feet)" (emphasis added).

Please note that the agency is currently reviewing a rulemaking petition in which Blue Bird Body Company has requested that the agency amend

Standard No. 111, with respect to System A driving mirrors.

I hope this information is helpful. Please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.