Interpretation ID: 1983-2.42

TYPE: INTERPRETATION-NHTSA

DATE: 08/08/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Athey Products Corporation -- Roderic A. Esmonde

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Roderic A. Esmonde, P.E. Athey Products Corporation Capital Equipment Division P.O. Box 669 Raleigh, NC 27602

Dear Mr. Esmonde:

This responds to your recent letter concerning the requirements of Safety Standard No. 205, Glazing Materials. You enclosed a sample of a rigid plastic you would like to use on the side windows of street sweepers, and asked whether the standard would be applicable to that type of material.

Safety Standard No. 205 specifies performance and location requirements for glazing materials to be used on motor vehicles. Only those materials that are specified in the standard may be used on a vehicle, and only in the vehicle location specified for each glazing type. Thus, the sample you enclosed may be used only if it qualifies as one of the glazing types (Items) specified in the standard. A specific piece of glazing material qualifies as a particular glazing Item under the standard if it meets all of the performance tests specified in the standard for that Item. For example, your sample would be considered an Item 12 rigid plastic, which could be used in the vehicle locations specified for that glazing type, only if it passes all of the tests specified in the standard for Item 12 plastics.

Whether or not your sample does qualify as a permitted glazing Item under the standard will have to be determined by your company. The agency does not provide advance approval for any motor vehicle or piece of motor vehicle equipment. It is the manufacturer's responsibility to determine compliance with the Motor vehicle safety standards and to certify that compliance.

I would also note that the glazing manufacturer is required to certify, by markings etched on the material, any piece of glazing which is to be used in a motor vehicle (see S6. of Standard No. 205). These required markings would include a specification of the glazing type, e.g., "Item 12." The glazing sample you enclosed should be from a piece of certified material if that material is to be used on your motor vehicles.

Sincerely,

Frank Berndt Chief Counsel

JulY 12, 1983

Mr. Hugh Oates, Compliance Division

Dear Mr. Oates:

Please find attached a copy of our letter of June 15, which we fear must have gone astray.

We would appreciate your cooperation in giving us an early response so we may proceed further with our plans.

Roderic A. Esmonde P.E. Director of Engineering

June 15, 1983

Mr. Hugh Oates, Compliance Division, NHTSA

Dear Mr. Oates:

This will confirm our recent conversation regarding glazing materials for the front and side windows of street sweepers.

Motor Vehicle Safety Standard #205 defines the requirements for glazing materials for use in motor vehicles and motor vehicle equipment.

Section S5.1.2.1. Item 12 Rigid Plastics, and Section S5.1.2.2. Item 13 Flexible Plastics, define where these materials can be used.

We have been seriously considering using some form of Rigid Plastic for the side windows of the street sweepers we build. We enclose a sample piece of this material.

Would you be so kind as to advise us if the subject regulation also applies to this specific type as well.

Your kind cooperation and guidance is gratefully appreciated since we are, as such, neophytes in this area.

Yours very truly, ATHEY PRODUCTS CORPORATION

Roderic A. Esmonde, P.E. Director of Engineering

RAE/pfw

Enclosure Omitted.