Interpretation ID: aiam3654
Secretary/Treasurer
Pulse Marketing Group
Inc.
P.O. Box 1324
Elkhart
IN 46515;
Dear Mr. Kenny: This responds to your recent letter requesting information concernin Safety Standard No. 205, *Glazing Materials*. You are considering marketing a fiberglass reinforced plastic part' that would replace rear windows in buses. You ask whether the standard would be applicable.; The answer to your question is yes. Safety Standard No. 205 specifie performance and location requirements for all glazing materials used on motor vehicles, whether as original equipment or replacement parts. As a manufacturer or fabricator of glazing you would have to certify that your fiberglass product complies with all applicable requirements of the standard. Standard No. 205, and the ANS Z26 standard which is incorporated by reference, specifies three types of plastic materials which may be used in the rear windows of buses (including rear side windows). These are Items 4, 5, and 12 glazing materials. Your fiberglass window may only be used in the rear windows of buses if it complies with the performance requirements of one of these glazing types (Items), i.e., if it passes all of the tests specified for one of these Items. The fact that your product is opaque does not preclude its use, since Items 4, 5, and 12 glazing materials do not have to comply with any luminous transmittance requirements.; You also asked if any approvals are necessary before you market thi product. The answer is no. The agency does not grant prior approvals of motor vehicles or motor vehicle equipment. Section 114 of the National Traffic and Motor Vehicle Safety Act provides that it is the responsibility of the glazing manufacturer or fabricator to determine compliance and to certify that its product complies with all applicable requirements of Safety Standard No. 205. The certification and marking requirements are prescribed in paragraph S6 of Standard No. 205. (I am enclosing a copy of section 114 of the Vehicle Safety Act, which is referenced in paragraph S6.); Please contact Hugh Oates of my staff if you have any further question. Sincerely, Frank Berndt, Chief Counsel