Interpretation ID: aiam1845
Product Engineering
Ventline
Inc.
P.O. Box 308
Bristol
IN 46507;
Dear Mr. Bickel: This is in reply to your letter of February 27, 1975, regarding the us of rubber-modified polypropylene plastic in a roof ventilator which you manufacture. You enclose a sample of the material.; A plastic material used in the roof ventilator of a motor home mus meet the requirement of Motor Vehicle Safety Standard No. 205 (49 CFR S 571.205). Our conclusion is based on the fact that ANS Standard Z26.1-1966, which is incorporated into the Federal standard, includes ventilators and openings in the roof of motor vehicles as locations in which glazing materials meeting the requirements of the standard are directed to be used. Any of the materials specified in ANS Z26, and the plastic materials added to the standard (items 12 and 13) on November 11, 1972, may be used in a roof ventilator of a motor home. We would consider such a ventilator to be a window' of the motor home.; The NHTSA has in the past amended Standard No. 205 to permit the use o new materials in vehicle locations following a manufacturer's petition for such an amendment. It appears from your letter that the use of polypropylene in roof ventilators would not create a safety hazard. However, in order for us to consider a change in the standard it will be necessary for you to provide us with information on the performance of this material. One way that manufacturers have provided us this information in the past is to have the material tested to the least restrictive requirements of the standard for any material which the standard permits to be used in the location desired.; I have enclosed a copy of NHTSA procedural rules (49 CFR Part 553 containing information on submitting a petition for rulemaking. Such a petition should contain the information I have referred to regarding the performance of polypropylene.; In your letter you ask for a code number should we determine that th material must conform to Standard No. 205. A code number, however, is issued only to a prime glazing material manufacturer, who is one who either fabricates, laminates, or tempers the glazing material. The request for such a code number must be made directly by the prime glazing material manufacturer.; Sincerely, James C. Schultz, Chief Counsel