Interpretation ID: aiam3308
Specifications Engineer
Thomas Built Buses
1408 Courtesy Road
P.O. Box 2450
High Point
North Carolina 27261;
Dear Mr. Tydings: This is in response to your letter of April 28, 1980, concernin Standard No. 111, *Rearview Mirrors*. Your letter refers to section 9.1 of the standard, but the question themselves are concerned with section 9.2 of the standard.; You asked whether the standard requires the use of mote than on outside crossview convex mirror on a schoolbus. Section 9.2 provides, in part, 'Each schoolbus, except those that are forward control vehicles, shall have a convex mirror...' The use of the singular noun 'mirror' means that only one convex mirror can be used to meet the requirements of section 9.2.; You also asked the agency to define the word, 'view' as that word i used in the portion of section 9.2 that requires the outside crossview convex mirror to be 'mounted so as to provide the driver a view of the front bumper...' As explained in the notice proposing the use of crossview mirrors, the purpose of the requirement is to 'address special problems of driver visibility associated with pupil transportation.' The agency explained that 'to reduce the danger of death or injury to school children it is necessary that the school bus driver have the fullest possible view of all sides of the vehicle, including the front' (40 FR 33829, August 12, 1975). Use of a crossview mirror allows the driver to see the area immediately in front of a stopped bus to be sure there are no children there, before moving the bus.; The agency used the word 'view' in its ordinary, dictionary sense t mean within the range of sight. Thus, most, but not literally all, of the front bumper must be visible to the driver by use of the crossview mirror to ensure that he or she can see children standing in front of the bus.; Please note that the agency's November 6, 1978, proposal (43 FR 51657 to upgrade the standard would establish new field of view requirements for the crossview mirror. If you have any further questions, please let me know.; Sincerely, Frank Berndt, Chief Counsel