Interpretation ID: aiam2586
Krystal Glass Co.
224 St. Francis Drive
Boulder Creek
CA 95006;
Dear Mr. Watson: This responds to your March 11, 1977, question whether the staine glass portholes manufactured by your company for use on van vehicles have to comply with Safety Standard No. 205, *Glazing Materials*. You contend that since the portholes are backed by complying safety glazing the intent of Standard No. 205 is met, even though the stained glass itself is not safety glazing.; The National Highway Traffic Safety Administration (NHTSA) cannot agre with your interpretation. Standard No. 205 specifies performance requirements for glazing material for use in specified locations in motor vehicles. All parts of your stained glass porthole windows must comply with the requirements of the standard. The safety glazing that backs your portholes could be damaged during a crash and the vehicle occupants could be exposed to the noncomplying stained glass. The NHTSA, therefore, disagrees with your conclusion that the intent of Standard No. 205 is met by the Krystal Glass porthole windows.; You should be aware that paragraph S6.2 of the standard requires prime glazing material manufacturer to certify each piece of glazing material that is designed as a component of any specific motor vehicle or camper pursuant to Section 114 of the National Traffic and Motor Vehicle Safety Act, as amended, (15 U.S.C. S 1381, *et*. *seq*.), and by marking the glazing with the 'DOT' symbol and a manufacturer's code mark. A prime glazing material manufacturer is defined as one who fabricates, laminates, or tempers the glazing material. A manufacturer's code mark is assigned by the NHTSA upon the written request of a manufacturer.; Enclosed is a copy of the ANS Z26 standard, as requested in you telephone conversation with Hugh Oates of this office.; Sincerely, Joseph J. Levin, Jr., Chief Counsel