Interpretation ID: 1984-2.29

TYPE: INTERPRETATION-NHTSA

DATE: 07/13/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Porsche

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Mayer D. Ing. h.c.F. Porsche AG Porschestrasse 42 Stuttgart-Zuffenheusen Germany

Dear Mr. Mayer:

Your letter of June 5, 1984, to Mr. Jettner was forwarded to my office for reply. You asked whether Porsche may use a trilingual marking on glass-plastic glazing. As explained below, the answer is yes.

Section 5.1.2.5(b) of Standard No. 205 requires manufacturers of glass-plastic glazing to permanently and indelibly mark the lower center of such glazing with the words, "Glass Plastic Material -See Owner's Manual For Care Instructions". The letter must be not less than 3/16 inch nor more than 1/4 inch high. You ask whether the optional marking permitted may be trilingual. As long as the English marking conforms to the requirements of section 5.l.2.5(b), there is no prohibition in the standard to using a trilingual warning.

I note that the pictures you enclosed with your letter appear to show a decal with the language required to meet the standard. As discussed in the preamble to the glass-plastic glazing final rule, the agency added section 5.1.2.5(b) of the standard to allow manufacturers to etch or otherwise permanently and indelibly mark the message on the glazing. Please note that the use of a plastic decal which could be removed or become illegible would not be deemed "permanent and indelible" by the agency.

Sincerely,

Frank Berndt Chief Counsel

Mr. Edward Jettber Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, SW. Washington, D.C. 20590 USA

ESV-My-re Weissach, June 5, 1984

Request for Clarification

Dear Mr. Jettner:

In February 1984 (Federal Register Vol. 49; No. 37; Pages 6732/6735 of February 23, 1984) Safety Standard 205, Glazing Materials, was amended to allow the use of glass-plastic glazing as windshields and windows in motor vehicles.

In relation with this amendment permission was given to affix a label on the window in order to give vehicle owner's cleaning instructions, S 5.1.2.5(b).

The text must be in letters not less than 3/16 inch nor more than 1/4 inch high, with the following words:

"GLASS PLASTIC MATERIAL - SEE OWNER'S MANUAL FOR CARE INSTRUCTIONS."

We are now asking for permission to add the corresponding cleaning instructions in German and French to this label.

The trilingual label would assure that the content of the instruction will be understood by the customers in most of the countries our vehicles are sold to, without the disadvantage of using different labels in production.

A uniform label would also prevent errors in the assignment of the labels to the different countries.

For better understanding we enclosed pictures showing the requested labels on our vehicles '911' and '928'.

Altogether, the dimensions of the label are small enough that the label can be affixed on the area underneath the windshield wipers (windshield wipers in resting position).

An early favorable answer of our request would be greatly appreciated as we intent to use the new windshields, which have a layer of polyurethan on the inner surface, on our new vehicles (1985).

We thank you in advance for your kindness and remain,

Sincerely yours,

Dr.Ing.h.c.F. Porsche AG -Technical Administration-Mayer Enclosure

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