Interpretation ID: aiam3955
Jr.
P. O. Box 52592
Houston
TX 77002;
Dear Mr. Pitts: Thank you for your letter of March 12, 1985, asking about the effect o our regulations on a product you would like to manufacture. I hope the following discussion explains that effect.; You described your product, which you call a glare- shield, as 1/8-inch thick sheet of 'Lexan' plastic with a special scratch resistant coating. Your product is designed to be mounted inside a motor vehicle, as close to the windshield as possible, to reduce glare-related vision problems caused by the sun. You stated that your product would cover the entire windshield and is designed to be held in place by three or six latches. The latches can be released by the driver and the shield can be removed from the car.; Pursuant to the National Traffic and Motor Vehicle Safety Act, we hav issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials,* (49 CFR 571.205) which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; Any manufacturer, dealer or other person who installs tinting films o other sun screen devices, such as the one described in your letter, in *new* vehicles must certify that the vehicle as altered continues to comply with the requirements of the standard. Thus, for example, the light transmittance through the combination of the sun-screening material and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the other applicable requirements of the standard, such as the abrasion resistance requirements.; After a vehicle is sold to the consumer, owners may themselves alte their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, an owner may install any device regardless of whether the installation adversely affects light transmittance. The agency does, however, urge owners not to install equipment which would render inoperative the compliance of a vehicle with our standards. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens on their vehicles.; If a manufacturer, dealer, distributor or motor vehicle repair busines installs the sun screen device for the owner of a used vehicle, then S108(a)(2)(A) of the Vehicle Safety Act may apply. That section provides that none of those persons may knowingly render inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a Federal motor vehicle safety standard. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; Sincerely, Jeffrey R. Miller, Chief Counsel