Interpretation ID: 86-6.26

TYPE: INTERPRETATION-NHTSA

DATE: 12/31/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. William Wallace

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William Wallace Assistant Manager Chemical Commodities New York City Transit Authority 25 Jamaica Avenue Brooklyn NY 11207

Dear Mr. Wallace:

Thank you for your letter of June 19, 1986, concerning how our regulations would affect the use of certain glazing materials in buses. You explained that the Transit Authority has recently contracted to have several hundred buses rehabilitated. As a part of that pork, the aide glazing of the buses was replaced with glazing that contained the following markings,"Lexan, MR 5000 sheet, ANSI % 26-1, Camplas, NY."

Subsequent to receipt of your letter, we received additional Information from General Electric, the manufacturer of Lexan, concerning the glazing material used in the side windows of your buses. According to General Electric, the Lexan glazing material used in these windows can meet all of the performance requirements set in Standard No. 205 for "AS-5" glazing materials. The glazing material apparently was not marked as "AS-5" material. As discussed below, if the only markings on the glazing are the markings you described in your letter, the glazing apparently does not comply pith the marking requirements of Standard No. 205, Glazing Materials.

Standard No. 205 specifies performance and location requirements for glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as "items" in the standard.) Plastic glazing materials, such as Lexan, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set for AS-5 glazing materials, It can be used in any window in a bus, except for the windshield, the windows to the immediate right and left of the driver, and the rearmost windows, if used for driving Visibility.

In addition to setting performance requirements for different items of glazing, the standard requires glazing materials to contain certain markings. The marking requirements of 56 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked with the AS number (which indicates that the material meets the performance requirements set for that "item" of glazing material), a model number and the manufacturer's logo. The information you provided about the markings on the glazing installed in your buses indicates that the glazing does not have an AS number marked on it.

Any glazing sold for use in a motor vehicle must conform to the applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, we have been in contact with General Electric to obtain further information about this possible noncompliance.

Our regulations do not preclude the Transit Authority from operating a vehicle with noncomplying glazing materials: however, you should check with State authorities to determine the effect of New York law on operating these buses.

Thank you for bringing this matter to the attention of the agency: If you need further information, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

June 19, 1986

Office of the Chief Counsel NHTSA 400 7th Street, SW Washington, DC 20590

Dear Sir:

The New York City Transit Authority recently contracted to have several hundred buses rehabilitated. As part of this process, the side glazing on these buses was replaced with glazing marked as follows:

LEXAN MR 5000 SHEET ANSI Z 26-1 CAMPLAS, NY

The Authority has questioned the legality of operating buses with this material and would appreciate any comments your office may have to offer regarding this matter.

Sincerely,

William Wallace Assistant Manager, Chemical Commodities