The following photos illustrate the problems described. Figure 1. Figure 2

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1 TRUCKS In the United States trucks are classified by the Government according to Gross Vehicle Weight (GVW). The classes important for the purposes of this paper are Class 3-8 trucks which run from 10,001 pounds to 33,001 pounds and over because these are the trucks that come under the exterior mirror requirements of the Federal Motor Vehicle Safety Standards (FMVSS) 111 that are set by the National Highway Traffic Safety Administration (NHTSA). These trucks are all various weights, are generally referred to as large trucks, and all are all used for a variety of purposes. For operator visibility purposes all of these trucks have the same general characteristics that are set forth in UMTRI Truck Mirrors, Fields of View, and Serious Truck Crashes (hereafter UMTRI ) by Daniel Blower, at page 1 In a large truck, the driver s view around the vehicle is significantly more restricted than in other vehicles, especially in passenger vehicles. In trucks, the driver s view of the near-field is significantly obstructed by the structure of the vehicle. The rear of the cab and the cargo body obstructs the view directly to the rear, even with mirrors. The driver can directly view the area along the left side of the vehicle by a head turn in some cases, though even that view is restricted by the width of the cargo body and the design of the cab. Along the right side of the vehicle, the driver s view is almost entirely dependent on indirect vision, using mirrors. The width of the vehicle limits the angular size of the field in the mirror to the right, and because of the height of the vehicle the driver s direct view of the lane next to the truck can be blocked by 1

2 the part of the door below the window. In similar fashion, the view of the area immediately in front of the truck is obstructed, particularly by the hood of a conventional cab. The following photos illustrate the problems described. Figure 1 Figure 2 2

3 UMTRI also states at page 1: The regulatory requirements for mirror systems on trucks are minimal in comparison to common practice. Federal Motor Vehicle Safety Standard (FMVSS) 111 requires only that there that there be a planar mirror on each side of the cab with an area of at least 323 square centimeters. There are no federal requirements for other mirrors or that pertain to blind zones around the vehicle. The number of mirrors that are commonly used in addition to those required show that many truck operators have attempted to address the problem. Truckers often add convex mirrors near the planar mirrors, look down mirrors on the passenger side door, and fender/hood mounted convex mirrors, mounted to fill in the blind zone along the side of the vehicle, or to provide a view of the area immediately in front. The agency charged with the safety of the travelling public, NHTSA, whose stated mission is, Save lives, prevent injuries and reduce economic costs due to road traffic crashes, through education, research, safety standards and enforcement activity. ( emphasis supplied) on August 12, 1975 mandated that large trucks have only a 7 inch by 7 inch flat glass mirror on each side of the cab for operator visability. There have been no changes to that standard for a period of 37 years. In spite of all types of remedies tried to cure the blind spot problem by operators over these 37 years. The agency charged with creating safety standards has not taken any action except to continually research the problem. The public has even tried to get the Agency to respond to the problem of blind spots. In September of 1999 Ms. Barbara Sanford filed a petition with NHTSA asking them to amend FMVSS 111 to require that all commercial trucks travelling on the interstate highway system have 3

4 convex mirrors mounted on their front right and left fenders. Ms. Sanford was involved in an accident while her car was in a blind spot by the front of a truck and she claimed that when convex mirrors are mounted on the front fenders they eliminate a blind spot that is caused by the driver s elevated position with respect to most passenger cars. The agency granted her petition on May 21, 2001 and set her petition Docket No up for a Request for Comments on January 15, In its initial filing NHTSA stated at page 2999 Federal Register Volume 68 the following: Prior to the Sanford petition, the agency had decided to conduct research on heavy truck mirror systems, including fender mounted mirrors. The objective of the study is to assess side and rearward visibility of heavy trucks, document current mirror design and aiming, develop a method to evaluate mirror fields of view, and recommend enhanced mirror design and aiming. The study should be completed by the Fall of It is to be noted that NHTSA did not consider petition to be significant so there was no a compliance with Executive Order so NHTSA could not as a result of filing this petition make any change to the FMVSS standards anyway. On October 3, 2005 NHTSA withdrew its action on Petition simply restating the quote stated above. Finally, in May of 2006 in UMTRI Prioritizing Improvements to Truck Driver Vision by Matthew P. Reed, Daniel Blower and Michael J. Flannagan (hereafter UMTRI ) at page 1 we find: Recently the National Highway Traffic Safety Administration (NHTSA) has requested information on whether fender-mounted convex mirrors should be required***. The agency had decided to examine mirror systems on large trucks prior to September of 1999 but did not even request such a study until a in

5 The only action really taken by the Federal Government on the topic of blind spots is the NO ZONE campaign launched in As stated on the Federal Motor Carrier Safety Administration website; Its goal is to increase awareness of the No-Zones---danger areas like blind spots around commercial vehicles in which cars disappear from the view of the truck or bus driver. No- Zones are areas where crashes are more likely to occur. Educating drivers about the No-Zones may reduce deaths, injuries and property damage from these kinds of crashes. and its executive summary of the program is provided: Educating motorists on techniques to share the road safely is an important safety issue. In recent years, more than 400,000 crashes involving large trucks result in more than 5300 deaths. The principal Campaign goal is to increase motorist awareness of commercial motor vehicle (CMV) limitations. The No-Zone represents areas around trucks and buses where vehicles are not visible to truck and bus drivers, thereby increasing the risk of a crash. One of the stated purposes of the Campaign was to reduce car-truck related fatal crashes by 10% over a 5 year period. Logos were developed representing the N0-Zone areas around trucks such as follows, the logo developed by FMCSA. 5

6 Even organizations such as the American Trucking Associations developed its own logo. The final report on the project in June of 1999, included no reference to the goal of a 10% reduction of car-truck related fatal crashes as had been projected. FMCSA and NHTSA knew current mirror systems were not working and rather than consider new mirror technology decided to focus on electronic methods of replacing mirrors. On the FMCSA Technology Division web site where is found the following statement: The National Highway Traffic Safety Administration (NHTSA) and FMCSA have a joint project underway with the Virginia Tech Transportation Institute (VTTI) involving the use of Camera/Video Imaging Systems (C/VSSs) in large trucks to improve visibility. In the first phase of this project, both mirror surrogates and enhancements are being studied and tested. Mirror enhancements provide the driver with images that are presently unavailable from standard mirror configurations (e.g. elimination of blind spots). Mirror surrogates provide the driver with the same or similar images that are available from standard mirror configurations. (emphasis supplied) To my knowledge there have been no published reports on accidents prevented by these systems as a result of Phase 3 of the program which was supposed to entail actual fleets testing the results of the above program for a test period under normal driving conditions. Absent such information we have to assume that this program has not proven itself 6

7 yet to reach the conclusion that blind spots are no longer a problem on large trucks.(the real test will be whether the system works so well that NHTSA incorporates it into a mandate under the Federal Motor Vehicle Safety Standards). An examination of the Enhanced Camera/video Imaging Systems (E- C/VISs) for Heavy Vehicles: Final Report USDOT Document DOT HS provides the following, at page 1; The system was envisioned as an enhancement; that is the side mirrors would remain on the vehicle even though the video system was to be added. Under such circumstances, malfunction of any of the three video chains would still allow the heavy vehicle to be driven in a conventional manner. This statement would appear to indicate that the Federal Government has now decided that the video cameras are no longer being considered a surrogate (replacement) of existing mirrors but instead should be viewed as simply an enhancement of such systems. M-C North America contends a cheaper, easier and more operator friendly approach would be to simply enhance existing mirror systems. THE EXISTING MIRROR SYSTEMS FOR LARGE TRUCKS DO NOT PROVIDE THE DRIVER WITH THE NECESSARY INDIRECT VISION TO OPERATE THE TRUCK SAFELY. The above discussion makes it clear that the current system of a 7 x 7 flat glass mandated by the government along with the voluntary attempts of operators to use supplemental mirrors does not work and everyone, even the Government knows it. We are still left with the problem of blind spots. UMTRI at page 1 sets forth the premise that in all prior research on the topic very little attention has been expended on addressing the contributions of quantity and quality of the field of view that is required as they might affect the field of view to truck safety. It is submitted that this has been the problem from beginning. The federal government mandates a 7 x 7 inch flat glass mirror with no 7

8 studies as to the quality and quantity of the view provided and thereafter without any guidance operators begin to attach supplementary mirrors again with no regard to the quality and quantity of view these mirrors add to operator visibility and all the while truck crashes continue and people are killed and/or injured. And drivers surveys continue to report in passing the automobile, (Survey of 236 professional drivers in paper on Cost-Benefit Evaluation of Large Truck-Automobile Speed Limit Differentials on Rural Interstate Highways MBTC 2048 by Steven L. Johnson and Naveen Pawar University of Arkansas at page 106: For many of the truck drivers that contended that the time when the truck is pulling into the right lane is the most dangerous part of the maneuver, the issue of resistance of some automobile drivers to follow a truck was mentioned. It was contended that this concern sometimes results in the automobile driver speeding up when being passed by the truck, making it more difficult for the truck to re-ender the right lane. Visibility of automobiles in a potential blind spot was also cited as a cause of many accidents and near misses when re-entering the right lane. (emphasis supplied) In UMTRI the approach was to first do an extensive analysis of crash data from several sources to examine the role of driver vision in truck-initiated crashes. This is a difficult task because of the way accidents are reported, if they are reported at all, and what kind of data on the accident has been recorded. The study did provide insight to the problem. The crash data sources covered truck crash data for the time period of Over this time period of 7 years the truck crash total was 2,671,729. This total amount over the 7 year time period equals an average truck crash total of 381,676 per year. The sheer magnitude of the problem becomes very apparent. 8

9 The analysis of these truck crashes was done to categorize the crashes into mirror-relevant crashes with the DEFINITION OF A MIRROR- RELEVANT CRASH BEING ONE WHERE THE TRUCK OPERATOR ATTEMPTED TO EXECUTE A MANEUVER WHERE HE/SHE WOULD HAVE TO RELY ON THE MIRRORS ON THE TRUCK TO DECIDE IF THE MANEUVER COULD BE COMPLETED SAFELY. Six basic maneuvers were selected (as mirror-relevant) and accidents were examined with the available evidence to determine if the crash could fit into one of these 6 crash types, recognizing the difficulty with the information provided by the crash reports. The six mirror-relevant categories, and the respective number of crashes and their percentage of the total were stated: Crash type Number Percentage Truck,lane change/merge Right, into other vehicle 180, Truck,lane change/merge left, into other vehicle 41, Truck turns right, other vehicle in blind spot 94, Truck turns left, other Vehicle in blind spot 22,515.8 Truck starts up from stop Truck backs into other vehicle 186, Totals 525, (Table 2 UMTRI ) page 10 We will accept these figures, with the caveat that we feel the percentage of mirror-relevant crashes is between 30-40% from discussions with operators. This would simply amplify the magnitude of the problem but not change the analysis. The definition used by the researchers covers only situations where the truck operator decided to make a maneuver and had to rely on the mirrors, but there are many situations where the 9

10 driver was not looking to make a maneuver but became the focus of an accident which could have been avoided or maybe happened because of inattention to the mirrors. Drivers are constantly educated to continuously scan their mirrors. For example as set forth in Tip #4 on the FMCSA web site tips titled: Inadequate Surveillance. Tip # 4 Check Your Mirrors Often Check your mirrors regularly (at least every 5 to 8 seconds) and before you change lanes, turn or merge. Check your mirrors quickly and return your attention to the road Ahead. Frequent scanning will allow you to be aware of changing traffic conditions around your truck. Did you Know? If you check your mirrors regularly, they can help you spot overtaking vehicles. Mirrors will also help you monitor your surrounding environment and may help you identify if a vehicle has moved into your blind spot. Did you Know? You can also use your mirrors to check your tires As you are driving down the road which may help you spot a tire fire. In addition, you can use the mirrors to check for loose straps, ropes or chains when you are carrying open cargo. Clearly this recognizes that the exterior mirrors on the truck are the method by which the operator maintains continuous contact with the operating environment of the vehicle. The effect and types of crashes caused by such situations are not quantified in the normal data bases set up by the government but they still exist. The researchers for UMTRI then analyze where the truck was struck as a part of the crash as part of a program to illustrate the areas on the truck that are more critical in the crash scenario, concluding at UMTRI at page 42: Truck crashes in which the driver must rely on mirrors to move to the right are significantly overrepresented in comparison with left moves. LCM (lane chang/merge) right crashes occurred over four times more frequently than LCM left crashes. Similarly, turn at intersection crashes (turn right crashes) in which the conflict comes 10

11 from the rear are over four times more frequent in right turns than in left. The distance from the driver to the right-side mirror and the relatively smaller image in the mirror makes maneuvers to the right more risky than similar maneuvers to the left. And further at page 42 states: In sum, the area to the right of the truck, particularly right forward is clearly significantly overrepresented in certain crash types. In lane changes crashes, movement to the right is overrepresented by over four times compared to movement to the left, and the problem is exacerbated at night and in dark/lighted conditions. In low speed maneuvers involving pedestrians and other nonmotorists, the fact that the truck driver is largely unable to view the immediate vicinity of the vehicle places the burden of avoiding a collision largely on the other parties around the truck. Populations that are less mobile are especially vulnerable. The critical areas are immediately in front and to the right of the truck. The researchers in UMTR then set up an empirical test of mirror systems being used, stating in relation to their test, at page 45, that: This approach will allow us to develop a model of visual difficulty to account for the major findings in the crash data, and, more importantly for practical considerations, make valid predictions about the efficacy of various countermeasures, such as innovative mirror systems, to reduce problems with visual difficulty. For the test a tractor-trailer (with a 45 foot trailer) was set up in a parking lot and six professional truck drivers were paid to participate in the study. A car, a 1993 Nissan Altima was the object. Three mirrors were mounted on each side of the tractor: a flat (west coast) mirror, a window mounted convex mirror and a fender mounted convex mirror. The tractor-trailer was parked at one end of the area so that the passenger car could be placed in a variety of positions alongside or behind it. The car was then placed at various positions and the drivers were requested to, using any combination of the mirrors, signify that 11

12 they felt the car was either in a position to interfere with a lane change or not. The drivers were instructed to make the decision as quickly as possible. Various tests were then conducted using either the 3 mirrors outlined, or a combination of flat glass and window mounted convex, or a combination of a flat glass and fender mounted convex. Reaction times and number of correct responses under both daylight and dark situations were accumulated. What follows are some of the conclusions of the test: At page 60: The empirical results for driver visual performance are consistent with the crash data described in Section 2. There appears to be converging evidence for a visibility problem on the right side, toward the front of the tractor-trailers. Preliminary results for three different mirror systems are not conclusive, but suggest that the best visual performance may result from an innovative system in which a fender-mounted convex is used to replace, rather than supplement, the currently standard window-mounted convex mirror. At M-C North America this conclusion has bearing on our position that the importance of the location of the mirrors on the vehicle has never been properly considered. At page 78: The experimental study presented in Section 3 provides one approach to comparing detection performance with direct view and convex mirrors. For example, the drivers took approximately twice as long to detect a vehicle directly to the right of the cab using a convex mirror as they did on the left side of the vehicle using predominantly direct vision. and, Anecdotally, a convex mirror has a sweet spot corresponding to a distance from the mirror at which a pedestrian is most easily detected. If the pedestrian is closer, the distortion creates 12

13 problems with identification. If the pedestrian is further from the mirror, the distortion and minification may make the pedestrian difficult to detect. An appropriate performance-based scoring system is needed that would appropriately account for the differences in quality of view. Both of these conclusions will be discussed later in this paper on our discussion of the effect of Distortion presented by the convex mirror used as the supplementary mirror by the industry. Also on page 78: As noted above, the reaction-time paradigm, using direct-vision or planar-mirror detection time as a control, may be a good metric for establishing the relative quality of view provided by different systems.) and, on page 80, The experimental paradigm presented in Section 3, also represents a promising approach to evaluating the quality of exterior vision provided by alternative systems. The time drivers require to determine if a conflict exists provides a sensitive measure of the difficulty of the task. These conclusions will be discussed later in this paper under our discussion on the clarity issue of mirrors used in the exterior mirror systems. Based upon the above analyses the researchers then set forth a diagram outlining the priority areas on the truck, stating on page 63: One objective of this study was to determine which aspects of driver vision most required improvement. 13

14 Figure 28 from UMTRI THE M-C MIRROR TECHNOLOGY SOLUTION Prior to seeing the above 2 UMTRI reports M-C North America Inc. had made it s own study of blind spots on large trucks. We had been advised by many operators that blind spots still existed no matter what supplementary mirrors they added to the flat glass system required. The required flat glass left blind spots and space and size limitations precluded making this mirror any larger in size so we focused on the standard convex mirror that was and still is being used by all mirror manufacturers providing mirrors for the truck industry. The first phase of our study was to determine the field of view provided by existing mirror systems. We first studied the field of view provided by examining actual truck systems and used as our guage, when did the mirrors on the truck first show the operator the ground on the side of the vehicle. The first vehicle studied was a tractor-trailer vehicle with a 53 foot trailer (the common system in use today). The vehicle contained on each side a flat (west coast) mirror with a standard convex mirror located beneath the flat glass. Sitting in the seat we marked the location the mirrors first showed the ground and then imposed these findings on a photo of the truck involved, an illustration of which is found in the following Figure 3 14

15 Figure 3 As you will note from Figure 3 the view of the mirrors starts at the face of the mirror and expands as distance is travelled from the face of the mirror to the rear of the truck. Consequently, we concluded that this cone shape of viewing area left a blind spot along the side of the truck that started at the face of the mirror and ran to the position where the ground was first shown. People, objects and even cars could be in this area and would not be visible to the truck operator. The height of this blind spot at its highest point would be the location of the mirror on the truck which we found averaged 51 inches. Since lane changes and turning maneuvers require a view of the area out from the side of the truck we next placed markers at the edge of the view provided and super-imposed these findings out from a picture of a truck. Figure 4 illustrates our findings: 15

16 Figure 4 Here we found that the viewing area provided by the combination flat glass and convex glass totaled degrees, which left a blind area of approximately 60 degrees. We would normally expect the driver s peripheral view to cover 30 of this 60 degrees but the placement of mirrors on the door, considering the newer large case type mirrors, effectively blocks so much of the peripheral view as seen by the attached photos Figure 5 and 6 that we concluded the blind spot on the side of the truck is between 30 to 60 degrees. Figure 5 16

17 Figure 6 Examining tractor-trailer combination that contained a standard convex mirror on the front fender we found that the view along both the side of the truck and out from the truck could be expanded. This expansion of view with the standard convex mirror came with the introduction of a new problem (one that is consistently complained about by truck operators; DISTORTION Distortion is a basic fact of the standard convex mirror. The images produced by the mirror are smaller than in real life and this distorts the viewer s perception of where the object is located. The concept is referenced by UMTRI at page 42 as follows: The distance from the driver to the right- side mirror and the relatively smaller image in the mirror makes maneuvers to the right more risky than similar maneuvers to the left. and at page 78: Anecdotally, a convex mirror has a sweet spot corresponding to a distance from the mirror at which a pedestrian is most easily detected. If the pedestrian is closer, the distortion creates problems 17

18 with identification. If the pedestrian is further from the mirror, the distortion and minification may make the pedestrian difficult to detect. or as stated in by the Federal Government in NHTSA Petition 12347; The main difference between a flat mirror and convex mirror is that the image of an object viewed in a convex mirror is both, distorted and smaller than that of the same object viewed in a flat mirror. Therefore, such an object appears farther away and could be less recognizable when viewed in a convex mirror. Additionally, if the object were approaching or receding, its rate of change in position relative to other vehicles and its speed are more difficult to judge as well. For example, a driver who is not familiar with using a convex mirror on the passenger side may determine that it is safe to change lanes to the right, not realizing that a vehicle to the right rear is too close for the maneuver to be completed safely. Distortion develops as glass is curved to make it provide the wider view. With the standard convex mirror the more the glass is curved the more the distortion is increased. We found this to be true in the convex mirrors mounted on the fender. A given rate of curve would provide a given field of view and to expand that view the rate of curve would have to be increased thereby increasing the distortion. On page 80 of the UMTRI report there is reference to the reaction time necessary to see the problem and react to it and they conclude that using the flat glass as a control a good test of a potential mirror may be the reaction time between the flat mirror image as opposed to the reaction time using the tested mirror. We believe, that reaction time of the driver (the time between seeing the problem and taking evasive action ) is the most critical factor in the mirror system being of aid to the operator in avoiding crashes. We further believe that reaction time is made up of two components besides the view provided and they are: 18

19 CLARITY OF THE VIEW and LOCATION OF THE MIRRORS ON THE TRUCK PROVIDING THE VIEW CLARITY OF VIEW Distortion, if present requires the brain to make mental calculations as to the location of the object being viewed in relation to the subject truck and this process requires a longer time period of looking at the mirror to complete the calculation. This leads to slower reaction times and potential problems with upcoming traffic as the eyes are not focused on the area ahead. We decided early on that to provide Clarity of View would require a mirror glass that provided images that were so close to images presented in a flat glass mirror that the concept of distortion was eliminated. i.e. the proposed method of approach suggested in UMTRI LOCATION OF THE MIRROR ON THE TRUCK At the beginning of our analysis we questioned the standard location of the mirrors on the truck on the sides of the truck at the edge of the door. This required the driver, every time it is necessary to look at the mirror, to take the eyes off the road ahead and turn the head to look at the mirror. Again the driver is not watching upcoming traffic. We have continuously advocated that the mirrors should be placed in front of the driver so they can be scanned easily while maintaining primary focus on the road ahead. The clarity of the view that is presented to the operator with this scan will enhance the driver s reaction time. This position maybe the reason UMTRI at page 60 found evidence to 19

20 suggest that the window convex should be removed and replaced by the convex mirror on the fender. THE M-C MIRROR Our goal with a new mirror technology was that we knew we had to provide a wide view and the images presented in that view had to be so close to the size of images presented in a flat glass mirror, that the images produced for the operator were close to real-time images that could be used to make faster judgments about what is seen in the mirrors. Considerable engineering expertise led us to the development of the M-C Glass. The M-C Glass is a multi-curvature glass which means that multiple rates of curvature compose the overall rate of curvature. For instance a glass with a 650mm overall rate of curvature would have incorporated into it rates of curvature ranging from to 350mm and up to 1250mm. These multiple rates of curvature allow us to control both the width of view provided by the mirror along with the size of images presented. Reducing time it takes to react to what is being seen, creates a synergy between the mirror and the operator. The glass is so unique it has been granted a U.S. Patent no What effect does the M-C mirror glass have on the field of vision? Some illustrations using our 6 x 9 in model spot mirror illustrate 20

21 Figure 7 In Figure 7 we have taken a Class 8 Dump truck with 2 drive axles and 3 tag axles and placed the M-C spot Mirror on a tripod on the right front fender. The vehicle had the equipment of a flat(west coast) mirror with an 8 inch convex mirror mounted below the flat glass. The green lines illustrate the field of view of the Flat Glass and the convex glass and the red line illustrates the expansion of the field of view starting almost straight out from the truck. The view provided by the M-C spot mirror completely covers the areas 1 & 2 of the Priority area Figure 28 from UMTRI The clarity of the view provided can be illustrated by the attached two photos Figure 8 and 9. This is a tractor trailer combination with a flat bed trailer and Figure 8 is a picture from the driver s seat looking at the convex mirror mounted below the west coast mirror on the passenger side. As you examine the picture, note carefully the image in the convex mirror. The truck located in the middle of the mirror is located at the immediate end of the trailer of the subject vehicle. The driver has to take the time to study the picture to reach the 21

22 conclusion that there is or is not enough clearance to make the lane change while at the same time not keeping the eyes on the road ahead. Studying the mirror will have a detrimental effect on the driver s reaction time. Figure 8 Figure 9 In Figure 9, a 8 x 8 inch M-C Spot Mirror is placed over the 8 inch convex. Looking again at the image the driver can see immediately that the truck along the side of the subject vehicle is in a position where a lane change should not be attempted. 22

23 Again relating to the field of view provided by the M-C Mirror Technology we attach Figure10. Figure 10 Here the vehicle is a 3 axle Class 8 tractor used by a construction company pulling a flat- bed trailer to haul large construction equipment from or to a site. The 6 x 9 inch M-C Spot Mirror was placed on the door below the west coast mirror to replace the 8 inch convex, and on the front fender mount to replace the 8 inch convex that had been used on this location. Truck operator reports that the view of the trailer now includes a view of the equipment being hauled, regardless of how wide it is. Another technology that we have developed to make the M-C Technology more useful in developing solutions for particular types of vehicles is that we have been able to find a way to incorporate two radii of curvatures in the same glass mirror without the need of having lines to separate the changes in radius. This makes the transition smooth for the operator and therefore he/she does not see the transition area that can disrupt the visual/thought process. With this the operator would gain in reaction time and again when coupled with proper location of 23

24 the mirror on the vehicle there need by no head movement necessary to garner all information the operator needs for the operating environment of the vehicle. So far here we have incorporated this two multiple rates of curvature mirror into the quarry truck industry. Figure 11 provides an illustrate of the view provided by this type of mirror. Figure 11 This mirror incorporates both a 2000mm radius of curvature for the major part of the face of the mirror and a border of 1000mm on the bottom, left side and top to expand the view in these areas to show the operator these areas for the safe operation of the truck. As you can see from the picture, the transition is not evident to the viewer. The necessary view and clarity are maintained. Two major manufacturers of mining and quarry equipment are already using this mirror on their new equipment as their operators have the same concern about blind spots as do members of the trucking industry. We are currently developing a mirror using the same technology for the trucking industry and importantly here the 2 cuts of glass allows us to not only cover areas 1 & 2 of UMTRI Priority areas but also if the location of the mirror is on the front fender we can also structure it to show the area to the front of the truck or the area in Priority 4. This 24

25 will only leave us Priority area 3 which is an area that cannot be seen by the mirrors and a full 360Solution would have to incorporate a video camera or other electronic method of covering this area. Continue to visit our webpage for updated developments in this mirror system and visit our Product page for current models available for sale. Contact us if you have any questions and/or would like to engage in working with us to develop a positive solution for your fleet. Richard T. Ince Safety Director M-C North America dince@m-cglobal.com 25