The school bus is considered by some to be the most comprehensively mirrored vehicle under the Federal Motor Vehicle Safety Standards set forth by the National Highway Traffic Safety Administration. Analysis of the rules shows this is not true. The rules set forth in FMVSS 111 for school buses can be summarized as follows:
2 Mirror systems are required:
System A the Driving Mirrors. These are located on the door area of the bus and a typical type of mirror that is used here is the case type mirror with both a flat glass and a convex glass in the same case. An example of a typical school bus mirror is shown in the attached photo:
These mirrors are required to be adjusted by the operator so that a view along side the bus of 12 feet from the center of the rear axle on the passenger side and 6 feet from the center of the rear axle on drivers side is seen before the bus can be operated.
System B the pedestrian detection mirrors. Located on the immediate front of the bus only designed to be used when the bus is stopped and loading or unloading children.
An illustration of the field of view provided on all school buses, as mirrored by the manufacturers and used by the operators, on the passenger side of the bus, can be illustrated by the next photo:
Note that the view provided by the mirrors leaves a large triangular-shaped blind spot along the side of the bus which can be 6-7 feet depending upon the location of the mirror on the bus preventing the driver from seeing anything in this area when the bus is moving. This same blind spot was found in every passenger carrying vehicle examined.
NHTSA first recognized the problem and danger this blind spot created and in 1992 implemented a rule that specified that the two mirrors together on the passenger side must show the ground below the surface of the mirror to an area 61 meters rearward from the surface of the glass to the back of the bus. The ground from the mirror to the back of the bus and beyond must be seen, The blind spot would be removed.
Mirror technology, that is still in use today, cannot perform this view requirement because of the distortion problem and in 1995 NHSTA, filed a correction amendment (60 FR 15690), and further amended the rule in 2004 by Docket No. NHST 2004-17471; the two driving mirrors on the right side of the bus must now provide a view:
Section 9.2 (b)(1) For the mirror system on the right side of the bus, the entire top surface of Cylinder N in figure 2, and that area of the ground which extends rearward from Cylinder N to a point not less than 61 meters from the mirror surface.
The ground from the mirrors location on the bus is no longer required. The blind spot has returned.
NHSTA recognized the danger this blind spot produced, eliminated it and then reversed itself and now allows the blind spot to remain. Of further interest is the statement by NHSTA in 16471 that states:
“The purpose of the standard is to reduce the number of deaths and injuries that occur when the driver of a motor vehicle does not have a clear and reasonably unobstructed view to the rear”.
NHTSA also justified this change by saying the area below the mirrors are shown by System B mirrors anyway so it not necessary to see the area in both sets of mirrors. The problem with this logic is that System B mirrors are not to be used when the bus is moving and if System A mirrors do not provide a view at this time the area remains blind. Vehicles do not run into objects while they are stopped but they do when they are moving. Unfortunately, this requires the driver to look into the passenger detection mirrors (System B mirrors) while the bus is moving to be able to see the area, while at the same time FMVSS 111 states system B mirrors are only to be used while the bus is stopped. Rather than seek a solution NHTSA just abandoned the users to cope with the problem.
The M-C mirror system is designed to provide the solution
VIEW OF ADJOINING LANES PROVIDED BY DRIVING MIRRORS
The adjustment of the driving mirrors to 12 feet out from the center of the rear axle provides the driver with a viewing area of 20 degrees. The blind spot along the side of the bus is clearly visible in the following illustration:
This blind spot prevents the driver from making lane changes or turns without turning to look into the area to see what is in the vicinity before turning or making the lane change. It is also submitted that this narrow field of view (12 feet) poses an extreme danger for a child advancing towards the bus at the time it is leaving the loading zone. A child could be late and running towards the bus and may not be seen as the bus pulls away and the child ends up under the rear wheels of the bus.
THE INTERIOR MIRROR ON THE SCHOOL BUS
The interior mirror on the school bus is not covered by the federal regulation. The Student Transportation Conference, which consists of representatives from all 50 states meets every 5 years and decides various requirements on school buses including the interior mirror:
The current requirements for the standard school bus is a 6 x 30 flat glass mirror located over the area of the drivers seat. This type of mirror produces a view that we see in this illustration.
Note this type of mirror leaves the operator blind as to the first few rows of seats, the area surrounding the driver and the door area.
