Interpretation ID: aiam3936
Acting Supreme Court Justice
Justices' Chambers
360 Adams Street
Brooklyn
NY 11201;
Dear Justice Kramer: Thank you for your letter of March 14, 1985, concerning a case pendin before you that involves tinted side windows in a 1980 BMW. You asked us to provide you with information concerning the marking that appeared on the windows. I hope the following discussion of our glazing standard and the significance of the window markings is of assistance to you.; NHTSA has the authority, under the National Traffic and Motor Vehicl Safety Act, (15 U.S.C. 1391 *et seq*.), to establish Federal motor vehicle safety standards for new motor vehicles. We have issued Standard No. 205, *Glazing Materials*, which sets performance and other requirements for different items of glazing used in new motor vehicles. (I have enclosed a copy of the standard that was in effect for 1980 model year cars. Also enclosed is the American National Standards Institute (ANSI) Standard No. Z-26 incorporated by reference in Standard No. 205).; The standard requires that glazing used in locations requisite fo driving visibility have a luminous transmittance of 70 percent. The agency has considered all windows in a passenger car requisite for driving visibility. Thus, the side windows of a new 1980 BMW imported into the U.S. would have had to comply with the 70 percent luminous transmittance requirement.; Section S6 of Standard No. 205 requires glazing to have four items o identifying information on it. The four items are: a manufacturer's identification code assigned by our agency, the model number of the glazing assigned by the glazing manufacturer, the manufacturer's trademark or distinctive designation and an 'AS' number indicating that it meets all of the performance requirements set for that glazing item number.; The markings you provided us from the side windows of a 1980 BM indicate the following. The marking 'DOT 25' and 'DOT 28' are code numbers assigned by this agency to prime glazing manufacturers. DOT 25 is the code number assigned to Flachglas AG of Bayern, Federal Republic of Germany. DOT 28 is the code number assigned to Vereinigte Glaswerke of Porz, Federal Republic of Germany. The markings 'M202' and 'MIOZ' (based on our experience with manufacturer's model number, we believe that 'MIOZ' is a transcription error and should read 'M102') are model numbers assigned by the glazing manufacturers. The markings 'AS 2' signify that the glazing meets the requirement set in ANSI Z-26 for AS 2 glazing materials. The requirements for AS 2 glazing materials include a requirement in section 4.2 of ANSI Z-26 that AS 2 glazing meet the 70 percent luminous transmittance test of section 5.2. We believe the marking 'Delodur - 1F Liz Sekurit' and 'Duro-Glas - 1F Liz Sekurit' are the trademarks or other distinctive designations assigned by the manufacturers. We do not know what the markings 'BS 5282T', D-295' and (sic)MD-291' represent, but we believe the latter two represent European manufacturer identification codes.; I hope this information is of assistance to you. If you have furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel