BLIND SPOTS ILLUSTRATED

On the pages that follow we examine vehicles traveling on our roadways or being used on construction sites, work zones, quarries, farms and mines.  Accident rates in all these areas continue to escalate and until operators and manufacturers put the proper emphasis on mirroring of their working vehicles, this increase will continue.

Simply expressing the goal of no accidents is not  enough, if your drivers are not given the tools they need, it is impossible for them to meet the goals.   Reliance upon government regulation or lack thereof, has led these vehicles to be mirrored as they are, and it appears that the government does not intend to do any more.     

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UNITED STATES POST OFFICE  (USPS)

The USPS operates approximately 200,000 vehicles of various types.  They mainly use tractor-trailers, the utility van or box truck, and a creation distinct to the Post Office, the Long Life Vehicle (LLV).

The discussion under our explanation of blind spots discusses the tractor-trailer and on this page we wish to look at the

box trucks and LLV’s.

The box truck or utility van

This is a very common type vehicle on the roadways. With minor various, they are used by the Post Office, FedEx, UPS, DHL etc. and most bakeries and snack producers.  They are usually used in very high traffic areas of the city for deliveries to stores etc. and encounter the full congestion of city driving.

This type of vehicle also illustrates an earlier statement on this web site that American mirror manufacturers have introduced no new mirror technology for the various industries and continue to re-package old technology that does not work.  On the box type trucks the same mirror configuration has been used by the manufacturers for the past 70 plus years, a 6.5 flat glass and a 6.5 x 6 convex mrror.  What kind of field of view do these mirrors provide.

Looking at a Post Office vehicle as an illustration:

The following photo has been altered to include an overlay of the field of view the mirrors on the vehicle produce and the blind areas on a vertical plane along the side of the vehicle.

As the photo illustrates an area from the mirrors location on the truck to where the ground level can first be seen in the mirror leaves a triangular shaped blind spot along the side and bottom of the truck, including the immediate right front area of the truck.  This location cannot be seen by the driver in the seat on the other side of the vehicle even by turning the head and looking. 

The following photo has been altered to include an overlay of the field of view and blind areas the mirrors on the vehicle produce on a horizontal plane along the side of the vehicle.

The combination flat glass and convex mirror provide the driver a maximum view of 30-35 degrees.  This in combination with the peripheral view leaves a blind spot along the side of the vehicle of approximately 30-35 degrees.  When the driver is changing lanes or making a turn objects or persons in this area cannot be seen by the driver either with direct vision or the mirrors on the vehicle. 

Another common problem with the box truck type vehicle is the location of the door- mounted mirrors on the truck on the passenger side.  The configuration of these vehicles all produce a small triangular window on each side.  The attached photo is from the drivers seat looking at the passenger side mirriors. 

The driver is forced to first focus on the small window to find the mirrors and then to look at what images the mirrors are producing.  It is submitted that this takes time and creates a problem that could be resolved by moving the location towards the front of the vehicle so the mirrors can be seen with a glance to the right side of the windshield.

Long Life Vehicle

This is a small vehicle designed to work along city streets from the curb where mail boxes are located.  The driver actually sits on the right side of the vehicle for easy ingress and egress that does not require getting into an out of the vehicle into moving traffic.  The dimensions of the vehicle are approximately 15 feet length, 7 feet high and 6 feet wide.  This vehicle is mirrored almost the same as the box truck discussed above, with some additions.  There is no window in the rear of truck allowing use of an interior mirror to see behind the truck.

Since the driver sits on the right side and, must when competing a stop, pull out onto the traveled portion of the roadway the mirroring on the left side of the vehicle become the most critical.  Here the solution has been to place a flat glass and convex split mirror on the door frame, a convex pointing across the front of the vehicle  and one pointing along the side of the vehicle both mounted on the left front of the truck.  A large convex mirror is placed at the top rear of the truck evidently to give the operator a view of the rear of the truck.   The following photo illustrates the mirror configuration on the left side of the LLV. 

PASSENGER TRANSPORT VEHICLES       


Reviewed here are vehicles that are designed to transport passengers such as transit buses, mini-coaches, school buses, motor coaches and vans.

Mirror systems on such vehicles must not only to show the proximity area around the outside of the vehicle (the exterior mirrors), but must also provide the driver at all times the ability to see the entire interior of the vehicle for both security and control purposes. ( interior mirrors).

TRANSIT BUSES

This type of vehicle is used by agencies to provide travel around metro areas.  Travel requires constant stop and go in heavily congested city traffic situations and depending upon the time of day the driver may have to contend with a very crowded bus. 

Operators of such vehicles are given little aid by the federal government as the FMVSS simply provides a 7 x 7 flat glass on each side of the vehicle when the vehicle is delivered to the buyer.  An interior mirror is required but it is not designed to provide any specific requirements as to how much view the mirrors provide.

CURRENT PRACTICE OF TRANSIT OPERATORS

With no guidance from the government, operators are left to choose from the market place various types of mirrors and combinations to provide the necessary view for the operator.  We examined many transit agencies and found some used just a single flat glass mirror, some used a case type mirror with a flat glass and a convex mirror included in the same case and some used just a convex mirror.  Whatever the mirror configuration of the exterior mirrors we found a combination of problems that are common to all, and this can be illustrated by the attached photo of a transit bus with viewing areas and blind areas outlined:

                      

This vehicle was equipped with a single 8 x 8 convex type mirror on each side. 

One of the common problems on all these vehicles is the blind area shown on the side of the bus from the location of the mirror to where the operator can first see the ground.  The largest portion of this blind spot is towards the door area where people would be expected to congregate cannot be seen depending upon the height of the location of the mirror on the bus.  Many agencies reported that the greatest number of their accidents were attributable to this blind area because the object was in the blind area and could not be seen by the operator in making a turning maneuver.   The standard convex mirror cannot be placed in such a way so this ground view is available to the driver in the driver’s seat.  

Depending upon the age of the bus another common area are high coin boxes that are located immediately to the right of the driver in the middle of the bus.  The entire right front of the bus is not visible to the operator in such situations.  If the problem exists it must be solved by the placement of a separate spot mirror on the outside front of the bus aimed at the area to be seen.  We have solved the problem at various transit agencies.

A large part of the transit bus travels involve lane changes and turns and it becomes equally important that the driver can see the adjoining lanes of traffic to know when a lane change can be safely made.  On the transit buses reviewed we found the view to the side of the bus was about 25 degrees and did not provide an adequate view of adjoining lanes for safe lane changes without the driver taking the time to look into the area before making the lane change.  Many times we found the convex mirror as the tool used to expand this view and then depth of perception of the driver in what the images show becomes a problem. 
M-C spot mirror technology with its multi-chambered glass provides a view of 2 ½ lanes along the side of vehicle and provides images that are not distorted.

Interior mirrors- on most vehicles examined we found that the operator could not see the area around the operator’s seat and the door area.  To view the passengers many different sizes of convex mirror were used so if a view of the entire area of the interior of the bus was displayed the images were distorted.  Because buses are not uniform in length different sized mirrors are necessary and with the lack of distortion of the M-C glass we can find a specific solution for your problem.

THE MINI-COACH

The mini-coach or mini-bus developed a lot of attention in our country with the advent of the Americans with Disabilities law that required access to public transportation for the disabled and senior citizens no matter where they may live.  A large group of small agencies developed to meet the need and since there were not a great deal of people needing the bus at any given time smaller buses were developed. 

Attached is a photo of the typical mini-coach marked with field of view and blind areas.

                

Next picture illustrates the typical mirroring we found on such vechicles.                      



A review of the photo shows that this vehicle suffers from many of the common problems found with the transit bus.
From the location of the mirror on the unit there is a blind area from the location of the mirror to where the mirror first shows the ground. (illustrated).  On the mini-coach this is even made worse by all the construction struts on the side of the bus for the doorway etc.  If these areas cannot be seen in the mirrors then they areas cannot be seen even if the operator turns the head to look.  One para-transit agency stated accidents in this blind spot accounted for over 30% of all accidents of the agency.
To correct the problem the spot mirror in the case should show the ground at the location of the mirror on the vehicle.

Further we found on this type of vehicle the area shown in the mirrors to the side of the vehicle was only 16-20 degrees.  Based upon this estimate the blind spot along the outside of the bus was about 45 degrees.  For interior mirrors we found all types and sizes, a common type of mirror is shown in the attached photo.



As shown the photo does not show all the seats clearly, so a disabled passenger in the back could be having trouble and the driver would not notice unless he/she turned around in the seat. Location of the mirror on the inside front of the vehicle is sometimes placed so high up that the operator almost has to stand up to look into the mirror to see the passengers.  The mirror should be placed so that it can be seen with a glance by the operator and should provide a distortion free image.

THE SCHOOL BUS

The school bus is considered by many to be the most comprehensively mirrored vehicle under the Federal Motor Vehicle Safety Standards set forth by the National Highway Traffic Safety Administration.  Anaylsis 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.
 
We are concentrating on the driving mirrors in this paper.

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 attached photo:



NOTE THAT THE VIEW PROVIDED BY THE MIRRORS LEAVES A LARGE TRIANGLUAR 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.

The interesting thing here is that 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, could not then 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”.
And of interest also is the fact that NHTSA justified this change by saying the area below the mirrors is shown by the System B mirrors anyway so it not necessary to see the area in both sets of mirrors.  The problem with this logic is that the System B mirrors are not to be used when the bus is moving and if the 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 leaves the driver being required to look into the passenger detection mirrors (the System B mirrors) while the bus is moving to be able to see this 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 illustrated by 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, rather what happens as the Student Transportation Conference, which is composed of representatives from all the 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 can illustrated,  as follows:



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.

THE MOTOR COACH

There is a tremendous variety of mirrors on these units.  A common example is illustrated by the attached photo”



The view provided along the side of the bus can be illustrated by the attached photo:



The same blind area along the side of the bus is evident in this vehicle also.   We even had one motor coach operator indicate that their biggest problem was the driver knocking down passengers standing by the  door as there was no way for the driver to see in this area with the mirrors on the bus.  On motor coaches we found that they types of mirrors used produced a field of view out from the side of the bus of 30-35 degrees leaving a blind spot along the side of the bus of 30-35 degrees necessary in lane changes and turning maneuvers.

THE PASSENGER VAN

Cargo vans and similar type vehicles have been placed in the passenger carrier situations.
Typical example is shown by the attached photo:



The difficulty with this type of vehicle is that based upon its weight it falls under the category of passenger cars in the Federal Motor Vehicle Safety Standards and the manufacturer places mirrors on these vehicles that are similar to car mirrors.  Everyone who drives a car knows that before lane changes and turns are executed they have to turn and look into the area to see that another car is not there.  The passenger van suffers from these same blind spot situations and it becomes impossible to introduce added mirrors in such a system so the only solution is to seek a change in the Federal Motor Vehicle Safety Standards that would inure to the benefit of both car and van drivers. 

CONSTRUCTION VEHICLES



Construction vehicles include a range of products, some of which are used both on the road and off the road such as dump trucks, and vehicles such as the front end loader, an off road vehicle

The Dump Truck

This is a straight truck, used by utility companies, delivery companies and trucking companies in its lighter version and as the dump truck for heavier applications such as construction, snow-plowing and highway work.  In the past these units have been historically mirrored using a flat glass mirror referred to as the west coast mirror and an 8 inch convex mirror below this with both mirrors mounted on the door frame.
Some manufacturers offer twin case mirrors and these types of systems for installation when the vehicle is purchased but most operators find that the twin case mirror does not provide the field of view that a split mirror system provides.   The answer is simple, you have two pieces of glass in the same box both designed to do different things and this requires them to work against each other with the result being a reduced view.

A typical dump truck arrangement with a west coast mirror and 8 inch convex mirror on the door produces a field of view as shown by the attached picture.




The picture also illustrates the better view that could be provided by the installation of the M-C Spot mirror on the front fender for the blind spot along the side of the vehicle and the additional view across the adjoining lanes for lane changes and turns.

Another common unit found in the construction area as well as in mining, aggregate quarries, garbage transfer stations and disposal sites
and various other industries is the front-end loader.  This vehicle is classified as an off-road vehicle so the National Highway Traffic Safety Administration rules do not apply and these vehicles would come under the jurisdiction OSHA generally, and in the mining area the Mine Safety and Health Administration.  Neither of these organizations have rules or regulations on exterior mirrors that are required to be followed by manufacturers of this type of equipment.  Manufacturers put such mirrors on this type of vehicle as they choose.

The major safety factor involved with the front-end loader is that it is usually working in areas where co-workers are working in proximity to the machine so it becomes especially important for the operator to see the area surrounding the unit.   

Examples of view provided by the manufacturers illustrate that the mirror systems do not perform the required functions.

First is an illustration of a Kawasaki  front- end loader, showing on a vertical plane, the view provided by the mirrors on the unit and the blind area along the side of the unit



Next is an illustration of the horizontal plane view on a Caterpillar front-end loader.



For large highway construction projects many contractors use the articulated dump truck.  The mirrors provided by the manufacturers produce the following viewing area on these types of vehicles:

 

 

MINING EQUIPMENT



Regulated by the Mine Safety and Health Administration which has developed no rules for exterior mirrors on this type of  equipment.
Historically, the type of vehicles used in the mining industry continue to get bigger and bigger.  Exterior mirrors get bigger and bigger and this really evidences the problems with distortion in the standard convex glass.   

Most mines work with the large front-end loader.  Picture attached illustrates one such a unit, a Letourneau L-1850 model.



This equipment is mirrored with a 12 x 20 inch convex mirror on each side of the cab.  This picture illustrates the view provided the operator in such a mirror:



The view is not adequate to provide proximity area protection and what is seen is so distorted as to be unusable by the operator.

The next picture is a typical mine truck with blind and viewing areas illustrated:

LOGGING EQUIPMENT


 
    There are no federal mirror requirements for the various types of products used in the logging industry.  A major problem with this type of equipment is the exterior mirrors are continually knocked off because of tree limbs encountered in the woods so often that many manufacturers simply put no exterior mirrors on their units.  The front-end loader is also a very used item in the logging industry and the reader should review the discussion above under construction equipment.





In most of the logging equipment where I sat in the operator’s seat the units are equipped with a small interior mirror. The view provided by a typical mirror is shown in the next photo:

One of the most dangerous occupations or industries is farming. There are no federal regulations governing the exterior mirrors on farm equipment.  Manufacturers include exterior mirrors on both sides where there is an enclosed cab and an illustration of what view these mirrors provide can be shown by a typical tractor with viewing area and blind areas illustrated:



Interior mirrors are also provided and the typical view for the operator is shown by the next photo:



 
The combine is a vehicle where the mirrors are located many times 10 feet from the ground level.  This leaves an extensive blind area along the side of the unit as shown by the attached photo with viewing area and blind areas illustrated






Richard T. Ince
Safety Director
M-C North America Inc.