Interpretation ID: 1984-3.19

TYPE: INTERPRETATION-NHTSA

DATE: 08/31/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: K. Yamada -- Technical Research Group, Toyota Motor Corporation

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/26/89 letter from Stephen P. Wood to Melanie Turner (A33; Std. 205); 4/13/78 letter from Joseph J. Levin to Moe Pare (Std. 205); 11/3/88 letter from Melanie Turner to Erika Z. Jones (OCC 2777)

TEXT:

August 6, 1984

Mr. Frank A. Berndt Chief Counsel NHTSA NOA-30 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

SUBJECT: Request for Clarification of FMVSS 205

According to FMVSS 205, the windshield glass of a passenger car must have marks on it, such as "DOT" and the manufacturer's code mark. But, we wonder if any problem would be caused from a compliance point of view if the mark were to appear underneath the moldings when the car was assembled? Please review the diagram below.

"INSERT"

I look forward to your reply. Thank you for your time.

Sincerely,

TOYOTA MOTOR CORPORATION K. Yamada Assistant Manager Technical Research Group U.S. Office

KY:gcm

U.S. Department of Transportation National Highway Traffic Safety Administration AUG 31 1984

Mr. K. Yamada Assistant Manager Technical Research Group Toyota Motor Corporation One Harmon Plaza Secaucus, New Jersey 07094

Dear Mr. Yamada:

This responds to your letter of August 6, 1984, concerning Standard No. 205, Glazing Materials. You asked whether the "DOT" symbol and manufacturer's code mark required by the standard must be visible when a windshield installed in a passenger car. You explained that the windshield molding may cover the required marks.

The certification requirements of section S6 of the standard do not require the markings to remain visible after installation the glazing on a glazing in accordance with the standard and as long as the markings are not removed by the vehicle manufacturer, there is no prohibition against covering the markings. The agency does, however, urge manufacturers to place the DOT symbol and manufacturer's code mark in a visible location whenever possible. Having the symbol and code in a vehicle location enables State motor vehicle inspection officials and U.S. Customs officials to easily determine if the glazing in the vehicle conforms to our standard.

Sincerely,

Frank Berndt Chief Counsel