Interpretation ID: aiam1324
Attorney At Law
420 Harvard Tower
4815 South Harvard Avenue
Tulsa
Oklahoma 74135;
Dear Mr. Hodgson: This is in reply to your letter of October 26,, 1973, requesting a interpretation of Federal Motor Vehicle Safety Standard No. 111, Paragraph S3.2.1.2 (Mounting).; Paragraph S3.2.1.2 requires, in part, that the outside mirror on th driver's side be capable of adjustment from the driver's seated position. The purpose of this requirements is to ensure that any necessary adjustment of the mirror can be readily accomplished without affecting the continued safe operation of the vehicle in motion. I for some reason the position of the outside mirror were altered so as to obstruct the clear view of the driver to the rear, he would be compelled to leave the highway and remove himself from the vehicle in order to make an adjustment. This possibility defeats one of the purposes of paragraph S3.2.1.2.; Paragraph S3.2.1.2 also provides that the mirror shall not be obscure by the unwiped portion of the windshield. As you stated in your letter, the curvature of the Traveco windshield will not afford an unobscured view of the mirror in that the mirror only retains about 80% of its visibility in the rain and snow. Visibility of 80% does not satisfy the requirements of Standard No. 111.; In summary, the mounting you have suggested for rearview mirrors on th Traveco motor homes is not in conformity with the requirements set out in Paragraph S3.2.1.2 of Standard No. 111. However, pursuant to section 108 (b)(1) of the Vehicle Safety Act, the nonconforming mirrors you have described may be installed if the installation is accomplished after the first purchase of the vehicle for purposes other than resale. You should also be aware that a revision of the standard is presently under consideration which may have an effect on the future compliance of the mirrors.; We appreciate your inquiry. Yours truly, Richard B. Dyson, Assistant Chief Counsel