Interpretation ID: nht67-1.17

DATE: 08/07/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Kar Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Dr. Haddon asked me to thank you for your letter of June 19 concerning certification procedures for your product.

Apparently our reply of June 14 did not reach you prior to your sending your second letter. I have enclosed a copy of this answer for your reference. This reply was based on the assumption that your KAR Safety Mirror was not original equipment but rather would be sold in the aftermarket.

Your second letter asks three questions. The first question states that the KAR Safety Mirror will be original equipment on a new Camper being introduced in 1968 and asks what steps, if any, must be taken to certify said mirror for this specific purpose. The answer to this question is that the certification obligation contained in Standard No. 111 applies to the vehicle and it is therefore the vehicle manufacturer who will have to certify that the vehicle needs all applicable standards including Standard No. 111. Question No. 2 concerns the transfer of mirrors from cars now equipped with the KAR Safety Mirror, and question No. 3 concerns the certification requirements on 1963 models where the owner installs the KAR Safety Mirror as an after purchase add on piece of equipment. The answer to both of these questions, of course, is that there is no certification requirement at this time for the mirror, as such, as an item of motor vehicle equipment.

Thank you again for your interest in motor vehicle safety.

June 19, 1967

William Haddon, Jr., M.D., Administrator National Traffic Safety Agency

Under date of May 19, 1967, I wrote to you asking for guidance in submitting the KAR Safety Mirror to the proper local authority for certification under the provisions of the National Traffic & Motor Vehicle Act of 1966. The absence of a reply, to this date, would indicate you have not had sufficient time to implement this prodigious and important program. However, at the risk of being importunate, I earnestly inquire for answers to the conditions presented herein; namely,

1. The KAR Safety Mirror will be original equipment on a new Camper being introduced in 1968. What steps, if any, must be taken to certify said mirror for this specific purpose?

2. A number of owners now having cars equipped with the KAR Safety Mirror will trade for 1968 models and will transfer said KAR Safety Mirror to the new car immediately 'after purchase'. Is prior certification required under these circumstances? If so, how do we proceed?

3. Will prior certification be required for the KAR Safety Mirror when owners of 1968 models buy outright and install said KAR Safety Mirror directly 'after purchase' of the new car?

We would appreciate your comment and reply to these questions at the earliest practical moment.

Alan Axtell, President

cc Honorable George Murphy

cc Honorable Warren G. Magnuson

Will Scott Ford Motor Company

I see no objection to your request of June 28, 1967, to ship the outside mirrors loose in your Econoline models until reaching dealer destination. Since the mirror is shipped and the mounting holes are drilled at the factory, the installation of the mirror by the dealer is purely a routine dealer service.

Sincerely,

William Haddon, Jr., N.B.

DR. WILLIAM HADDON JR DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU FEDERAL HIGHWAY ADMINISTRATION WASHINGTON D C 20591

PARAGRAPH S3.2.1.1 OF STANDARD NUMBER 111 SPECIFIES THAT AN OUTSIDE REAR-VIEW MIRROR QUOTE SHOULD BE INSTALLED UNQUOTE ON APPLICABLE VEHICLES. IT HAS JUST BEEN BROUGHT TO MY ATTENTION THAT FORD ECONOLINE MODELS ARE SHIPPED WITH OUTSIDE MIRROR LOOSE IN VEHICLE. THIS PRACTICE IS FOLLOWED BECAUSE OF RESULTING INSUFFICIENT CLEARANCE FOR LOADING ON LOWER LEVEL OF HAULAWAY VEHICLES IF MIRROR IS INSTALLED AT FACTORY. ECONOLINES EQUIPPED WITH MIRRORS COULD, OF COURSE, BE SHIPPED ON UPPER HAULAWAY LEVEL ONLY BUT SHIPPING DELAYS AND FREIGHT PENALTIES THAT WOULD RESULT FROM UNDERUTILIZATION OF EQUIPMENT MAKE SUCH A PLAN UNREASONABLE.

WE DRILL MIRROR MOUNTING HOLES AT FACTOR TO INSURE THAT MIRROR IS IN FACT, INSTALLED BY DEALER PRIOR TO CUSTOMER DELIVERY. WOULD THIS BE ACCEPTABLE TO BUREAU OR WILL IT BE NECESSARY TO CLASSIFY THESE UNITS AS IMCOMPLETE VEHICLES SORRY TO BOTHER YOU WITH THIS DETAIL WHEN BUREAU HAS FAR MORE IMPORTAND SUBJECTS UNDER CONSIDERATION REGARDS

WILL SCOTT FORD MOTOR AUTOMOTIVE SAFETY DIRECTOR CENTRAL OFFICE BLDG DEARBORN MICH