Interpretation ID: 1984-3.1

TYPE: INTERPRETATION-NHTSA

DATE: 08/09/84

FROM: AUTHOR UNAVAILABLE; David W. Allen; NHTSA

TO: Orient Glass Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Y. Higuchi Executive Vice President Orient Glass, Inc. 445 South Figueroa Street, Suite 2430 Los Angeles, CA 90071

Dear Mr. Higuchi:

This responds to your letter of July 19, concerning the requirements of Standard No. 205, Glazing Materials. You specifically asked whether a temporary haze which develops on a test specimen of glass-plastic glazing during Test No. 4, Boil test, constitutes a failure of that test. As explained below, the temporary haze would not be considered a failure of the boil test requirement.

As you correctly noted, Standard No. 205 requires glass-plastic glazing to pass the Test 4 boil test, of American National Standards Institute Z-26, which is incorporated by reference in our standard. As explained in the preamble to the November 16, 1983, final rule setting performance requirements for glass-plastic glazing, the purpose of the boil test is to ensure that the plastic layer of glass-plastic glazing does not delaminate when exposed to high temperatures and humidity.

You explained that during your test of a piece of glass-plastic glazing, a "haze developed all over the plastic side at the end of the test." You further stated that the "haze totally disappears in 24-36 hours" when the specimen is returned to "ordinary room temperature." Since the temporary haze does not result in a permanent change in the structure of the glazing, which would occur if the glazing delaminated, we do not consider the temporary haze to be a failure of the boil test. The glazing must, of course, comply with Test No. 17, Abrasion resistance, which is directly meant to limit haze.

If you have any further questions, please let us know.

Sincerely,

Frank Berndt Chief Counsel

JULY 19, 1984

Office of Vehicle Safety Standards, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590 (Attn: Mr. Edward Jettner)

Re: Glass-Plastic Glazing Materials

Dear Mr. Jettner:

The undersigned is writing this letter on behalf of Nippon Sheet Glass Co., Ltd. (Herein after referred as NSG) a potential manufacturer of "Glass-Plastic Glazing Materials" defined in Safety Standard NO. 205 Glazing Materials (49 CFR 571.205).

With reference to the amendment of Safety Standard NO. 205 Docket NO. 81-04: Notice 4 NSG understands that " Glass-Plastic Glazing " have to pass the Test N0.4 (Boil Test) provided in ANS Z 26. In regard of Test NO. 4 on "Glass-Plastic" NSG wants to confirm that the following interpretation is correct.

When NSG conducted the Test N0.4 on Securiflex, which was made by Saint Gobain Vitrage of France, haze developed all over the plastic side at the end of the test. NSG believes that this haze comes out due to the direct contact with boiling water for as long as two hours. NSG observed this haze totally disappeared in 24 - 36 hours when the said Glass-plastic specimens were kept at ordinary room temperature. NSG, accordingly, interprets this temporary haze shall not be considered as "Other defects" provided in ANS Z 26.

Your competent comments on NSG's observation and interpretation would be highly appreciated.

Truly yours,

Y. Higuchi Executive Vice President

cc: Mr. Mizutani (NSG) Mr. Todoroki (NSG)