Interpretation ID: aiam2242
President
Werner Incorporated
P.O. Box 310
10861 Straits Hwy.
Cheboygan
MI 49721;
Dear Mr. Werner: This is in response to your letter of November 20, 1975, concernin certification of your company's roof vents as being in compliance with Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*.; In our correspondence to you of August 25, 1975, we stated that roo vent covers of the type your company manufactures are subject to the requirements of Standard No. 205. However, we also stated that the National Highway Traffic Safety Administration (NHTSA) concurred in the view that roof vent covers manufactured by the injection molding process were not susceptible to testing under the procedures found in USAS Z26.1. Further, we informed you that the NHTSA intended to issue proposed rulemaking that would establish a surrogate testing procedure for these roof vent covers, and that until this was done the NHTSA would not take action against manufacturers who did not certify that their injection molded covers met the requirements of Standard No. 205.; Upon further consideration and review, however, the NHTSA ha determined that it must retract its earlier concurrence in the view that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures specified in USAS Z26.1.; The earlier concern that the USAS Z26.1 test procedures wer inappropriate for testing the covers was based upon the fact that the USAS tests call for 'substantially flat specimens'. Manufacturers of the roof vents contended that covers manufactured by the injection molding process were not 'substantially flat' in their finished condition or at any time during their manufacture, and hence could not be tested for compliance with USAS Z26.1 requirements.; The NHTSA has since concluded that manufacturers can test their roo vent product under the procedures specified in USAS Z26.1, and thereby certify compliance with Standard No. 205. The USAS tests do not require the test specimens to be cut from the actual product--in this case the roof vent covers. Therefore, although the vent covers themselves are not 'substantially flat,' it is possible to mold flat specimens of the same material for purposes of the USAS tests. Consequently, it is not necessary that the NHTSA issue new surrogate testing procedures.; Since this is a reversal of our previous position, the NHTSA will no consider this interpretation to take effect with respect to glazing manufactured before September 1, 1976.; Please contact us if we can be of any further assistance. Sincerely, Frank Berndt, Acting Chief Counsel