Interpretation ID: aiam2685
Grand Teton Trading Co.
Box 2436
Jackson
WY 83001;
Dear Mr. Ducey: This responds to your letter of September 12, 1977, requestin information concerning the certification requirements for acrylic glazing to be used in motor vehicles. Specifically, you are interested in the separate certification responsibilities of the company that manufactures the acrylic sheets, the company that cuts and shapes the acrylic, and the company that constructs aluminum frames around the acrylic and sells windows to the customized van market.; Paragraphs S6.1 and S6.3 of Safety Standard No. 205, *Glazin Materials*, specify that prime glazing material manufacturers shall certify each piece of glazing that is for use in motor vehicles in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, *et seq*.) and with section 6 of the ANS Z26 standard. These requirements would be applicable to the company from which you buy acrylic sheets, since that company would qualify as a prime glazing material manufacturer.; As a manufacturer or distributor who cuts a section of glazing for us in a motor vehicle, your company would be required to certify its product in the same fashion as your supplier (paragraphs S6.4 and S6.5 of Standard No. 205). Please note, however, that under section 6 of ANS Z26 your company is required to mark any section of glazing that it cuts with the same words, designations, characters, and numerals as the piece of glazing from which it was cut. This means that you would stamp your product with markings identical to the certification markings on the acrylic sheets you purchased.; The company that constructs aluminum around the glazing and sell windows to the customized van market would be required to certify its product in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act. Section 114 provides that an item of motor vehicle equipment (including glazing) may be certified by means of a label or tag on the item of equipment or on the outside of a container in which the equipment is delivered. The label or tag must certify that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, Standard No. 205 in this case.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel