Interpretation ID: nht78-3.2

DATE: 01/25/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 14, 1977, inquiring whether attaching mirrors onto the backs of sun visors on the passenger's side would violate S3.4.1 of Motor Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact -- Passenger Cars.

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, so long as the mirror does not cause the visor to be hazardous or to interfere with the energy-absorbing requirement of S3.4.1, manufacturers are free to incorporate such mirrors into or onto sun visors, including fitting mirrors onto the backs of the sun visors on the passenger's side as in the diagram you enclosed.

SINCERELY,

Toyo Kogyo Co., Ltd.

December 14, 1977

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Mr. Levin:

We are considering to attach a mirror to the sun visor for customers' convenience. However, since MVSS 201 provides for the following requirement, we would like to have your comment as to whether we can meet it by doing so.

MVSS 201 "Occupant Protection in Interior Impact"

S3.4 Sun visor

S3.4.1 Two sun visor shall be provided that are constructed of or covered with energy-absorbing material.

The mirror will be fitted into the back of the sun visor on passenger's side as shown in the attached sheet. We consider that this would be in compliance with the above requirement on the grounds that the sun visor made of energy-absorbing material would not contact the occupant under normal condition, thus would not produce an adverse effect on the safety of the occupant.

We would appreciate hearing from you on this matter as soon as possible.

Moriyuki Watanabe Director and Assistant General Manager Research and Development

CC: TOYO KOGYO USA REP. OFC., DETROIT BRANCH

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