Interpretation ID: nht80-3.6

DATE: 06/20/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Thomas Built Buses - James Tydings, Specifications Engineer

TITLE: FMVSS INTERPRETATION

ATTACHMT: 8/26/88 letter from Erika Jones to Frank Reynolds (Std. 111; A32)

TEXT: This responds to your letter of April 28, 1980, concerning Standard No. 111, Rearview Mirrors. Your letter refers to section 9.1 of the standard, but the questions themselves are concerned with section 9.2 of the standard.

You asked whether the standard requires the use of more than one outside crossview convex mirror on a schoolbus. Section 9.2 provides, in part, "Each schoolbus, except those that are forward control vehicles, shall have a convex mirror . . . ." The use of the singular noun "mirror" means that only one convex mirror can be used to meet the requirements of section 9.2.

You also asked the agency to define the word, "view" as that word is used in the portion of section 9.2 that requires the outside crossview convex mirror to be "mounted so as to provide the driver a view of the front bumper. . . ." As explained in the notice proposing the use of crossview mirrors, the purpose of the requirement is to "address special problems of driver visibility associated with pupil transportation." The agency explained that "to reduce the danger of death or injury to school children it is necessary that the school bus driver have the fullest possible view of all sides of the vehicle, including the front" (40 FR 33829, August 12, 1975). Use of a crossview mirror allows the driver to see the area immediately in front of a stopped bus to be sure there are no children there, before moving the bus.

The agency used the word "view" in its ordinary, dictionary sense to mean within the range of sight. Thus, most, but not literally all, of the front bumper must be visible to the driver by use of the crossview mirror to ensure that he or she can see children standing in front of the bus.

Please note that the agency's November 6, 1978, proposal (43 FR 51657) to upgrade the standard would establish new field of view requirements for the crossview mirror. If you have any further questions, please let me know.

SINCERELY,

April 28, 1980

Chief Counsel Office of Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

Subject: FMVSS #111-76 Rearview Mirrors

Dear Mr. Chief Counsel: The subject standard states in Section S9.1 that each school bus shall have a convex mirror.

Since the singular tense is used, a school bus having one (1) convex mirror would be deemed to be in compliance, is this correct?

Further on in this section, the Standard speaks. . . . "And mounted so as to provide the driver a view of the front bumper . . ."

We would appreciate it if you would furnish us a definition of the word "view" as used in this standard.

Thanking you in advance, we remain

THOMAS BUILT BUSES, INC.

James Tydings Specifications Engineer