Interpretation ID: aiam4345
Division Quality Control Manager
LSI Safelite
801 South Wichita
P. O. Box 1879
Wichita
KS 67201;
Dear Mr. Harris: This responds to your letter of February 17, 1987, concerning the us of a DOT code number on glazing material by someone other than the prime manufacturer. I regret the delay in our response. You indicate in your letter that a customer has requested that you, as the prime manufacturer of the glazing material, include in your trademark on each piece of glazing material the DOT code number issued to you. You refer to the particular glazing material in question as 'stock glass', since a customer purchases sheets for glazing material from you and then cuts the glazing into pieces for various unknown applications. You object to this request, because you have no control over the use to which the glazing material will be put. You request our opinion and we offer the following.; The marking and certification requirements for glazing materials ar continued in S6 of Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, and include different marking requirements for a prime manufacturer and other types of manufacturers. (A prime glazing material manufacturer is defined in S6.1 as one who fabricates, laminates, or tempers the glazing material.) The only glazing material which *must* carry the DOT code mark is that produced by a prime manufacturer and designed as a component of a specific motor vehicle or camper. Since you specifically indicate that you do not know the use of which the glazing material will be put, there is no *requirement* that this glazing material carry your manufacturer's code.; The purpose of the manufacturer's code is to help the agency identif the actual manufacturer of the glazing material for the purpose of defect and noncompliance recall campaigns. The difference in the marking requirements was designed to help the agency distinguish between glazing in a motor vehicle that had been manufactured by the prime manufacturer specifically for use in that vehicle and glazing that had been cut, shaped, or otherwise altered before installation. In a July 13, 1976, letter to 'Lucite' Acrylic Sheet Products, we stated that the certification requirements had become widely understood and uniformly practiced throughout the glazing industry, which has aided the traceability of glazing for enforcement purposes. We went on to say that, for these reasons, we were no longer prohibiting the use of the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of the code number to the distributor or manufacturer.; In summary, you may include, if you wish, your DOT code number o glazing material not designed for use in a specific motor vehicle or camper, but sold by you to others. There is no obligation to do so, however. If you have further questions please feel free to contact us.; Sincerely, Erika Z. Jones, Chief Counsel