Interpretation ID: nht79-2.1

DATE: 09/14/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Tiger Trading Corporation International

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 26, 1979, concerning an "after market" motor vehicle accessory you plan to distribute. You describe the accessory as an item of clear plastic that affixes to the inside of the rear window "to greatly improve the rear vision of the driver of a passenger vehicle."

Standard No. 111, Rearview Mirrors, establishes performance requirements for rearview mirror systems. The standard only applies to mirrors installed as original equipment in motor vehicles and does not apply to replacement equipment such as the aftermarket accessory you intend to distribute. However, since the device you plan to distribute is an item of motor vehicle equipment, the recall and remedy provisions of the National Traffic and Motor Vehicle Safety Act (the Act), as amended, (15 U.S.C. 1411-1420) would apply to any safety-related defect in your mirror accessory. A copy of the Act is enclosed.

If you have any further questions, please let me know.

Sincerely,

July 26, 1979

Office of Chief Counsel National Highway Traffic Safety Administration

To Whom It May Concern:

We will be distributing a new automobile accessory to the retail trade selling "after market" accessories to the public. Following my brief phone conversation with Mr. Joseph F. Zemaitis, NHTSA, San Francisco, we deemed it advisable to check with your offices to determine if there will be any objections to the product.

Basically the article is made of plastic (clear) and is designed to greatly improve the rear vision of the driver of a passenger vehicle. The unit is affixed to the inside of the rear window by means of a self-adhesive mounting bracket. The driver when looking at the rear view mirror, with the field of vision passing through the unit rearward, then is capable of seeing objects on either side of their vehicle, which they cannot normally do so (Illegible Word) viewing through the rear view mirror.

The unit is 9"x3"x1" (rectangular) and is out of the way of any passengers. As it is not permanently mounted to the vehicle, it will break away upon impact. There are no sharp edges and the larger flat portion of the unit faces the interior of the vehicle. We have enclosed photocopies which will enable you to better understand the unit.

In light of the current problems with rearvision from the drivers seat, we believe the product is needed and timely. Your office's concern in this area as evidenced by Docket No. 71-3a;Notice 4 is indicative.

Your earliest comments will be appreciated.

David H. Lewis Import Manager

cc: Joseph F. Zemaitis

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THIN METAL TO ELIMINATE SUN GLARE (FACES WINDOW)

CLEAR PLASTIC FACING INTERIOR OF VEHICLE

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THIN METAL TO ELIMINATE SUN GLARE (FACES WINDOW)

PLASTIC

CLEAR PLASTIC FACING INTERIOR OF VEHICLE

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