Mirror Width - Another Regulatory Question

Thanks Macca. I agree that for the purposes of this discussion, 'width of vehicle' would include any (legal) fixed bodywork on the tow vehicle, and the width of a trailer while attached to the vehicle.

Most caravans would be around 2400mm wide not including awnings, sidelights, antennae etc?

Awnings must be included in the "actual" width, side lights are not, from memory.
Cheers,
Peter
OKA196 motorhome

Thanks Peter. In that case the LH mirror can stick out further than the RH..... :-)

For the record:
Vehicle:2003 HDJ100 Landcruiser GXL
Nom vehicle width (from factory sec sheet): 1940mm
Mirrors: Clearview Next Gen
Measured mirror width retracted: 2335mm = 395mm wider than vehicle (allowance = +500mm so meets
requirements)
Measured mirror width extended: 2650mm = 710mm wider than vehicle (exceeds requirements).
However my van is at least 2400mm wide (not incl awning), so 2650-2400=250mm, well within the ADR
requirements.

GOOD to see the word RETRACTED instead of FOLDING being used, because if using mirrors, when you don't need them for a wide trailed vehicle, FOLDING them means NO mirrors in use for the tow vehicle, whereas, slid in or out or extended and retracted means different to FOLDING.
Many people speak of folding as being retracted for some reason, and everyone is expected to know what is being meant.

Andrew, what are you referring to when you say 'Its 4.5t in NSW'?

There are a lot of requirements that change at a GVM of 3.5T.

Specifically, for mirrors, ADR 14, sect 3.3 APPLICABILITY TABLE describes the different ADR Vehicle Codes depending on GVM (and other criteria)
https://www.legislation.gov.au/Details/F2014C01366

This one is QLD-specific but likely similar in all States:https://www.legislation.qld.gov.au/view/pdf/2013-08-01/sl-2010-0192 Refer sect 24 & 25 for mirrors.

Now this presents an interesting, and I'd say unintended consequence.
EXAMPLE:
If we had two identical Landcruiser wagons (MD1 vehicle code, Ref ADR 14/02 sect 3.3. ) they are allowed mirrors that sit 250mm further out than the width of the vehicle (ADR 14/02 sect 15.2.2.6.)
However, if we then do a GVM upgrade on one 'Cruiser such that it's GVM is now 3.5T-4.5T it becomes an MD3 vehicle code and restricted to mirrors of only 230mm (folding). Refer APPENDIX C – ADR 14/02 - REAR VISION MIRRORS para 4.3

I'd be interested to see the wording on the infringement notice. It would at least be worth writing a well-written letter to see if he can get off without needing to contest it in court (that would depend on the wording of the infringement notice though). However, even if he can get the defect cleared, he may still be at fault if he had them extended without a trailer on.

They were over width while retracted.

Do you know what brand they were?

Ivan,

It would be interesting to know where the width of the vehicle was measured that determined the mirrors were over width when retracted.

The wording in the ADR’s state the mirrors can be no more than 150 mm wider than the widest point of the vehicle when retracted. The widest point of most 4WD’s is between the out edges of the mudguards, as they are generally flared. If you have permanent “add on flares”, that would make the vehicle even wider.

It sound like the person who inspected the vehicle for compliance, may have made a mistake.

Macca.

Measurements are to vehicle factory spec. You cant modify something and then use that as the base. Adding flares doesn't make a vehicle legal.

Clearview mirrors are 427mm retracted. Thats nearly 1/2 a metre and can I ask Macca what your automotive qualification is?

ADR 14
2.3.1.2. Mounting - The mirror mounting shall provide a stable support for the mirror and neither the mirror nor the mounting shall protrude further than the widest part of the vehicle body, except to the extent necessary to produce a field of view meeting the requirements of Clause 2.3.1.1. The mirror shall not be obscured by the unwiped portion of the windscreen, and shall be adjustable from the driver’s seating position. The mirror and mounting shall be free of sharp points or edges that could contribute to pedestrian injury.

Hi Ivan,

I do not have to have any automotive qualifications to read what is required in the ADR’s. I will need to recheck the wording of the remaining section of the ADR’s that you have posted, as I seem to recall there was a figure quoted with regard maximum protrusion of the external mirrors, of course, I am happy to be corrected if I have misread this section.

The Next Gen Clearview mirrors when retracted are 351 mm from the mounting point. The mounting point of the mirrors is not necessarily the widest point of the vehicle, as I stated earlier it is generally the distance between the outer edges of the mudguards. In my case, the mudguards are more than 150 mm wider each side than where the mirror is mounted on the “A” Pillar. I do not have aftermarket flares on the mudguards.

Macca.

Quote "Measurements are to vehicle factory spec. You cant modify something and then use that as the base. Adding flares doesn't make a vehicle legal."

There are vehicles out there where they have had to add flares so they do make them conform to the ADRs. This happens when longer axles are put under the vehicles or wider tyres were fitted. Are you telling me that is just not on and you can not modify a vehicle by adding wide tyres?

Nomadic Navara: Longer axles require an engineers ticket and this has nothing to do with mirrors

McLaren3030: Clause 2.3.1.1. is to do with vision to the rear on a standard body. In a ute it would be the tub

Macca, Ivan, if you go back up to one of my prior posts you'll see where I've referenced the ADR for overall width of mirrors. It's up to 250mm each for an MD1 code vehicle, and 230mm each side for a MD3 code vehicle.

Furthermore, I'd be using the factory specification for the vehicle width (as I've shown in the calcs above for my landcruiser). I get it that people add flares to cover wider tyres etc, but in most cases that's simply to comply with the ADR relating to tyre coverage/mudflaps. Those 'mods' don't formally amend the recorded width of the vehicle itself (these things are never cut-n-dry unfortunately).

So for Ivan's customer, if the retracted mirrors total width is within 500mm of the total vehicle width, I'd be arguing it in court. He might still cop the original fine (because they were unnecessarily extended), but should be able to clear the defect with those mirrors fitted (and retracted).

I'd love to see the link to the ADR that has a measurement because the ADR listed on the Federal Gov site doest have a measurement but has a formulae to work it out

The whole ADR APPENDIX C – ADR 14/02 - REAR VISION MIRRORS

2. REQUIREMENTS FOR LEP; MA; MB; MC; AND MD1 VEHICLES ONLY

2.0. Any internal rear vision mirror fitted to a vehicle and intended to provide the driver with a view of following or overtaking vehicles shall have a flat reflecting surface i.e. of unit magnification.

2.1. An external mirror complying with the requirement of Clause 2.3 shall be fitted on the driver’s side of the vehicle. An internal rear vision mirror shall also be provided except where the design of the motor vehicle does not provide for internal rear vision. In any case where the field of view requirements of Clause 2.2.1 are not met the vehicle shall be equipped with a passenger’s side external rear vision mirror complying with Clause 2.3.2.

2.2. Internal Rear Vision Mirrors

2.2.1. Field of View - An internal mirror shall be installed that provides all drivers (with eyes located by the ‘95th Percentile Eye Ellipses’ tangent contours) with a view to the rear, with an included horizontal angle of at least 20 degrees and sufficient vertical angle to provide a view of a level road surface extending to the horizon beginning at a point not greater than 61 metres to the rear of the vehicle when the vehicle is occupied by the driver and 4 passengers or the designated ‘Seating Capacity’, if less, based on 68 kg average occupant mass. The line of sight may be partially obscured by seated occupants or by ‘Head Restraints’.

2.2.2. Mounting

2.2.2.1. The mirror mounting shall provide a stable support for the mirror, and shall provide for adjustment by tilting in both horizontal and vertical directions.

2.2.2.2. If the mirror is in the ‘Head Impact Area’, the mounting shall deflect, collapse or break away without leaving sharp edges when the reflective surface of the mirror is subjected to a force of not more than 400 N in any ‘Forward’ direction that is not more than 45 degrees from the ‘Forward’ longitudinal direction.

2.3. External Rear Vision Mirrors

2.3.1. Driver’s Side

2.3.1.1. Field of View - A flat external mirror shall be installed that provides all drivers (with eyes located by the ‘95th Percentile Eye Ellipses’ tangent contours) with a view of a level road surface extending to the horizon from a line perpendicular to a plane tangential to the driver’s side of the vehicle at the widest point and parallel to the longitudinal axis of the vehicle, extending 2.4 metres out from the tangential plane 11 metres behind the driver’s eyes, with the ‘Seat’ in the rearmost position. The line of sight may be partially obscured by rear body or wheel guard contours. A convex mirror complying with the technical requirements of Appendix A may be used instead of a flat mirror.

2.3.1.2. Mounting - The mirror mounting shall provide a stable support for the mirror and neither the mirror nor the mounting shall protrude further than the widest part of the vehicle body, except to the extent necessary to produce a field of view meeting the requirements of Clause 2.3.1.1. The mirror shall not be obscured by the unwiped portion of the windscreen, and shall be adjustable from the driver’s seating position. The mirror and mounting shall be free of sharp points or edges that could contribute to pedestrian injury.

2.3.2. Passenger’s Side

2.3.2.1. Where a left-hand external mirror is provided in compliance with Clause 2.1 its mounting shall provide a stable support for the mirror. The mirror and mounting shall be free of sharp points or edges that could contribute to pedestrian injury. The mirror need not be adjustable from the driver’s seating position, but shall be capable of adjustment by tilting in both horizontal and vertical directions.

2.3.2.2. The mirror shall be flat or convex.

2.3.2.3. For ‘Convex Mirrors’ the reflective surface area is to be equal to or greater than that of a flat mirror required to meet the field of view requirements set out in Clause 2.3.1.1.

2.4. Mirror Construction

2.4.1. Reflectance

The reflectance value of the reflective film employed shall be at least 35 per cent. If a mirror is of the selective position prismatic type, the reflectance value in the night driving position shall be at least 4 per cent.

2.4.2. ‘Convex Mirrors’

Each motor vehicle using a ‘Convex Mirror’ to meet the requirements of Clause 2.3.2 shall comply with the following requirements:

2.4.2.1. the radii of curvature shall not deviate by more than plus or minus 15 per cent from the average radius of curvature when measured in accordance with the procedures specified in Annex 1.

2.4.2.2. the average radius of curvature is not to be less than 1,200 mm.

2.5. Test Procedure

2.5.1. Reflectance shall be determined in accordance with SAE document J964a "Test Procedure for Determining Reflectivity of Rearview Mirror", August, 1974.

2.5.2. The horizontal angle is measured from the projected eye point rather than the plane of the mirror.

3. REQUIREMENTS FOR VEHICLES OF CATEGORY LEG; NA AND MD2 ONLY

Vehicles of category NA, LEG and MD2 shall have mirrors which comply with Clause 2 or 4.

The only measurement is for MD3 and they have to be capable of folding down to a max of 150mm

4.2 At least one such mirror shall be affixed to each side of the vehicle and may project 150 mm beyond the point of ‘Overall Width’ of the vehicle or the ‘Overall Width’ of any trailer it may be drawing-

4.3. The mirrors may project 230 mm on each side beyond the point of ‘Overall Width’ of the vehicle provided that the mirror is capable of collapsing to 150 mm.

Thanks for copying the wording, I knew I had read somewhere in the ADR’s that there were actual measurements. Just couldn’t remember where, and I am in the middle of organising and packing for my trip to the Simpson Desert, leaving early this Sunday Sept. 3rd. so haven’t had time to go through it myself.

Macca.

Ivan, this is the link I've been referencing:https://www.legislation.gov.au/Details/F2014C01366

I believe a Landcruiser (wagon) or similar is an MC/M1 category ((Offroad Passenger Vehicle), not MD1/MD3 (light omnibus). Maybe that's a point of difference in our interpretations of the reg? Refer Applicability Table Para 3.3.

From para 15.2.2.6. : "Where the lower edge of an exterior mirror is less than 2 m above the ground when the vehicle is loaded to its technically permissible maximum laden mass, this mirror shall not project more than 250 mm beyond the overall width of the vehicle measured without mirrors."

And for para 4.3 of Appendix C, noting these are "REQUIREMENTS FOR MD3; MD4; ME; NB; AND NC VEHICLES ONLY." : "The mirrors may project 230 mm on each side beyond the point of ‘Overall Width’ of the vehicle provided that the mirror is capable of collapsing to 150 mm" .

I interpret 'COLLAPSING' to be folded back against the car if you hit something. So with the mirrors RETRACTED to their shortest extension, but still positioned so as to be useable, you have 230mm each side.

However, as para 4.3 App C doesn't apply to M1 or MD1 category vehicles, and as you say, there are no other width measurements in Appendix C, I would then default back to para 15.2.2.6 (250mm) for an M1/MD1 category vehicle.

Even my earlier model "elephant ears" can be folded in, albeit manually, so would never be wide enough to be an issue on a tray. Hopefully it never happens, but till that day one mirror gives a legal, stable and great view down the sides of the van and the smaller mirror allows me to visually monitor both the stonestomper and van tyres.