Interpretation ID: nht72-3.9
DATE: 09/01/72
FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA
TO: Rolls-Royce, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of May 19, 1971, concerning the placement of vanity mirrors in sun visors. We apologize for our delay in responding to your letter. The issues it raised, however, are of consequence to manufacturers other than Rolls-Royce, and concerned basic matters of interpretation of Standard No. 201 which have only recently been resolved.
The National Highway Traffic Safety Administration has determined that paragraph S3.4.1 of Standard No. 201 does not prohibit the installation by manufacturers of vanity mirrors on sun visors. Consequently, manufacturers are free to incorporate such mirrors into or onto sun visors, including mirrors that are recessed into the surface of the visor as in the sample you enclosed.
SINCERELY,
ROLLS-ROYCE, INC.
May 19, 1971
National Highway Traffic Safety Administration U.S. Department of Transportation
attention: Ref. FMVSS 201 Mr. Risteen
Gentlemen:
F.M.V.S.S. 201 OCCUPANT PROTECTION, INTERIOR IMPACT -- SUNVISOR, VANITY MIRRORS
The mirror was deleted from visors at the introduction of the Safety Standard. Customer criticism of the deletion of the mirror, however, has prompted us to seek the following interpretation, if in fact they would be regarded as acceptable:
We are aware that a Notice of Proposed Rule Making to Amend F.M.V.S.S. 205 - Docket 71-1; Notice 1 - glazing materials exist, where mirrors should meet the requirements of items 1 to 13 of ANS-Z26. With (Illegible Word) proposed effective date of January, 1972, however, it is hoped we will have material for the mirrors, but we are still not certain that it would qualify as energy absorbing.
The method of fitting mirrors to sunvisors to markets other than North America is:
1. 4-DOOR VEHICLES A plain glass mirror, backed with adhesive tape, so that should it fracture fragments adhere to the tape. The glass plus the tape is in a recess in the foam which makes up the body of the visor.
A thin gauge soft aluminum frame is used to tidy up the leather cover around the aperature.
2. 2-DOOR VEHICLES
A semi-rigid plastic mirror is used in a shallow recess in the foam. Again a frame is used to tidy up the trim around the aperature. In other respects the construction is the same.
In order to help in your interpretation, a sunvisor with the glass mirror and a sample of the plastic mirror is enclosed. If necessary, you may strip them down and break them if it will assist in arriving at a decision.
May we request an early response.
Trevor Williams Service Manager