Interpretation ID: aiam2349
Jr.
Marketing Specialist
'Lucite' Acrylic Sheet Products
1007 Market Street
Wilmington
DE 19898;
Dear Mr. Berry: This is in response to your letter of April 9, 1976, concerning th certification and marking requirements for glazing specified in Section 6 of Standard No. 205, *Glazing* Materials. You asked whether the standard prohibits use of the 'DOT' symbol and manufacturer's code number by anyone other than a 'prime glazing material manufacturer,' as that term is defined in paragraph S6.1.; Our letter to Dupont explained the separate certification and markin requirements that are applicable to glazing prepared by prime glazing material manufacturers, distributors, and vehicle manufacturers. The standard specifies that the 'DOT' symbol shall be placed on glazing that is designed by the prime glazing material manufacturer as a component of any specific motor vehicle. The agency's interpretations of several years ago pointed out that the standard requires a person other than a prime glazing manufacturer who cuts glazing materials to mark it in accordance with section 6 of ANS Z26 and to certify it in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act of 1966. These interpretations emphasized that a person who cuts and shapes the glazing material received from a prime glazing manufacturer should not include the 'DOT' symbol in his marking and certification.; At the time of the earlier interpretations, the NHTSA considered i necessary from the standpoint of enforcement to distinguish between glazing that had been manufactured by the prime glazing manufacturer for use in specific motor vehicles and glazing that had been cut, shaped, or otherwise altered by another party before installation. The agency was also concerned that the use of the 'DOT' symbol by anyone other than the prime glazing manufacturer would be misleading and could create confusion.; Since that time, the certification procedures have become more widel understood and uniformly practiced throughout the industry, and this has aided the 'traceability' of glazing materials for enforcement purposes. Therefore, the agency no longer prohibits the use of the 'DOT' symbol and the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of his code number to the distributor or manufacturer.; Sincerely, Frank Berndt, Acting Chief Counsel