Interpretation ID: nht92-8.40
DATE: February 29, 1992
FROM: Raymond B. Kesler -- Kesler Research Enterprises
TO: Administrator, NHTSA
TITLE: Petition
ATTACHMT: Attached to letter dated 5/14/92 from Paul J. Rice to Raymond B. Kesler (A39; Part 553; Std. 111)
TEXT:
PETITION
THIS IS A PETITION TO RECONSIDER AN EARLIER PETITION FOR RULE MAKING TO PROVIDE STANDARDS FOR THE REQUIREMENTS FOR AN IMPROVED, VEHICULAR CONVEX REAR VIEW MIRROR FOR DRIVERS OF MOTOR VEHICLES.
From Kesler Research Enterprises 5508 Cahuenga Blvd North Hollywood, CA 91601
To the Administrator
National Highway Traffic Safety Administration 400 Seventh Street, S.W., Washington, D.C. 20590
Kesler Research Enterprises hereby petitions the NHTSA to reconsider the earlier petition which Kesler presented to the Administrator under date of March 9th, 1991 regarding Kesler's proposal to amend the standards for passenger vehicles right side convex rear view mirrors by an appropriate rules change.
The March 9th, 1991 petition related to the use of a CAUTION RING INDICATOR (improperly identified at that time as a "Caution Ring Sensor) for drivers using passenger side convex rear-view mirrors.
This petition deals with an advanced wide angle rear-view mirror with a permanently etched in or other wise permanently affixed TRAFFIC RING INDICATOR thereon. It is also proposed herein that the mirror be provided with a 25-inch radius of curvature (roc).
PETITION FOR RECONSIDERATION BY KESLER RESEARCH ENTERPRISES
It is our understanding that a 25-inch radius of curvature gives the driver a wider field of view of the hazardous far lane when the petitioner's traffic ring indicator is present on the mirror and it includes the rear wheel area, in the event that a child might be there.
The ring indicator is particularly designed to be within the view field of the mirror providing comparison size information to the driver of all vehicles, including motorcycles within the viewing field. With the instruction given to the driver with the mirror he will readily learn to judge the fact that objects in the mirror are closer than they appear. Thus he is provided with a measure
of the location of the vehicle in the far lane and the fact that when it appears larger than the ring perimeter a lane change would be unsafe in the direction of the far lane even though seeking to change only into the adjacent lane.
A safe lane change would be possible only if the vehicle in the far lane appears smaller than the ring or at most no larger than the ring. As the vehicle in the far lane becomes larger an estimate of the closing speed of that vehicle can be judged and thus the driver will avoid the lane change until it is clearly safe. That is when the image is smaller than the ring.
It is clearly a fact that the extra wide field of view provides a way to avoid the well-known blind spot, reduce accidents on lane changes, and when backing out of driveways.
The CENTER FOR AUTO SAFETY has been made aware of the existence of the Kesler mirror. It was their organization who initially encouraged Kesler to petition for rule making to cover the mirror described above. It is respectfully suggested that the Agency reviewers may have misread the earlier petition. Kesler has wondered why the Agency reviewers had failed to request samples of the mirror for examination and test prior to the earlier judgement of rejection.
It is also true that most proposed driver or passenger safety devices on automotive vehicles, such as seat belts, extra brake light, air bag, etc., became optional equipment before they are approved for original equipment installation. Kesler feels that the proposed right side wide-angle rear view mirror should be approved to be made available to the driver as an optional choice and that appropriate rules be made to cover such mirrors.