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Interpretation ID: aiam3607

Mr. Donald J. Cameron, Director - Technical Support, New York City Transit Authority, 25 Jamaica Avenue, Brooklyn, NY 11207; Mr. Donald J. Cameron
Director - Technical Support
New York City Transit Authority
25 Jamaica Avenue
Brooklyn
NY 11207;

Dear Mr. Cameron: This responds to your recent letter asking whether the driver's sid window and the front entrance door window of a bus may be equipped with plastic glazing. You desire to use plastics because of the high operating cost of replacing broken glass windows.; The answer to your question is no. Safety Standard No. 205, *Glazin Materials*, was amended in 1977 to permit the use of rigid plastic glazing in all doors and windows of buses, *except* windshields or windows to the immediate right or left of the driver (42 FR 61465). The reason for this exception is that windows to the immediate right and left of the driver are necessary for driving visibility and typical plastic material used alone is not sufficiently resistant to abrasion. Plastic glazing would not be allowed in a bus entrance door since this would constitute a window to the immediate right' of the driver. Plastic glazing would be allowed in the rear emergency door, however, if that door was not necessary for driving visibility.; You also ask whether material other than safety glass may be used i either of these locations. I am not sure that I correctly understand your question. If by other materials' you mean, for example, sheet metal, the answer to your question would be yes. There are no Federal requirements specifying that a vehicle have windows in a certain location. Thus, theoretically, there would be nothing to preclude the installation of a solid metal entrance door in a bus. (Obviously, no manufacturer would likely do this because it would compromise driver vision.) If, however, there is a window and it is equipped with traditional glazing materials, the glazing must be in compliance with the performance and location requirements of Standard No. 205. If I have misunderstood your last question, please contact Hugh Oates of my staff and he will clarify the requirements for you (202- 426-2992).; Sincerely, Frank Berndt, Chief Counsel