Interpretation ID: 1982-2.31

DATE: 08/02/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: The Continental Insurance Companies -- William J. Benzie

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William J Benzie Corporate Fleet Coordinator The Continental Insurance Companies Eighty Maiden Lane New York, N.Y. 10038

Dear Mr. Benzie:

This responds to your recent letter asking about Federal regulations pertaining to automotive glass and to windshield repair kits. You are particularly interested in the Novus windshield repair method and ask if it has been approved by the agency.

The agency has issued Safety Standard No. 205, Glazing Materials (49 CFR 571.205), which specifies performance and location requirements for glazing used in motor vehicles. There are no standards or regulations specifically governing Windshield repair methods. However, I am enclosing a letter of interpretation which the agency issued in 1975 regarding the Novus method of windshield repair. I am also enclosing a letter of interpretation which discusses the general responsibilities of persons who modify or repair vehicles, including windshields, under the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381 et seq.). Please look closely at the third and fourth paragraphs of that letter.

Please note that the agency does not grant prior approval of any motor vehicle, motor vehicle equipment or method of vehicle repair. It is the responsibility of the vehicle or equipment manufacturer to certify that its products are in compliance with all applicable safety standards and regulations.

I hope the enclosed information will answer all of your questions.

Sincerely,

Original Signed By Frank Berndt Chief Counsel