Hindsighting your fleet – Considerations based on FMVSS 111
By now, you may be familiar (perhaps inundated) with information on rear vision systems for your vehicles. Applications and features of these systems have been expanding into more and more commercial vehicle applications. The technology can provide drivers and/or operational management with audiovisual data of what takes place in and around the vehicle. While vision systems are not new, under U.S. Federal Motor Vehicle Safety Standard (FMVSS) 111: Rear Visibility, new requirements have phased in, making them standard safety items on lighter vehicles. This has been the traditional standard for mirrors but now includes rear vision systems.
Safety benefits of these systems are immediate, giving the driver a view of the area directly behind the vehicle that mirrors cannot provide. Context is important as perspective on what is considered required can be different depending on use of vision system technology. Understanding key highlights of what performance demands are (and are not) included in these new requirements can help you incorporate vision systems in your fleet.
The new rear vision system requirements apply to vehicles with a gross vehicle weight rating (GVWR) of 4,535 kg or less, including trucks, buses, school buses and multipurpose passenger vehicles. The change to include rear vision systems in FMVSS 111 comes from the Cameron Gulbransen Kids Transportation Safety Act of 2007, in which National Highway Traffic Safety Administration (NHTSA) was directed to undertake a rulemaking process to expand the required field of view for drivers in order to reduce back-over accidents.
FMVSS requirements are typically performance-based and technology-neutral. However, camera/monitor system technology offered a practical and achievable path for NHTSA to enact performance requirements of this new portion of FMVSS 111 under the Congressional mandate. There are 7 performance requirements for rear vision systems, 2 of which are heavily influenced by camera positioning at the vehicle’s rear: field of view and image size. This is important to note as cameras may need to be replaced and/or relocated from their original factory position for completed vehicles being altered (i.e., pickup box removal). Field of view was the first of 7 performance demands to be required under phase-in; the other 6 (including image size) took effect May 1st, 2018. Vehicles completed from chassis-cabs, cutaways or other incomplete vehicles with a GVWR of 4,535 kg or less were not subject to phase-in requirements, but they need to meet the full set of performance requirements for incomplete vehicles produced on or after May 1, 2018. Conformance to the equivalent regulation in Canada is not required until 2019, and no phase-in period is included.
Some fleets are currently taking advantage of the performance requirements for field of view on heavier vehicles that do not require rear vision systems under FMVSS regulations. Whether required or not, new vehicles, or existing units being retrofitted, the standard offers a straightforward test for viewing the 3 m x 6 m space directly behind a vehicle and a series of 7 specifically sized cylindrical objects with either a horizontal band or vertical stripe applied.
As part of the test, the rear camera monitor view must provide the following:
Some common questions NTEA’s technical services department receives on rear vision system requirements include:
One of the other performance requirements – linger time – states that “the rearview image meeting the requirements of S6.2.1 and S6.2.2 shall not be displayed after the backing event has ended”. “Backing event” is defined in the standard, and the image for vehicles subject to the standard must be deactivated in the monitor, accordingly. In the rulemaking process, NHTSA cites the purpose for linger time: “…in order to ensure that the required rearview image is available to the driver at the appropriate time without becoming a distraction at an inappropriate time.”
Ongoing resources related to FMVSS 111 field of view conformity (including NTEA’s FMVSS 111 Field of View Conformity Manual and Kit) are available at ntea.com/fmvss111rearvisibility.
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