Interpretation ID: 1984-3.45

TYPE: INTERPRETATION-NHTSA

DATE: 11/29/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Wayne Ivie

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Wayne Ivie Manager, Support Section 1905 Lana Avenue, N.E. Salem, Oregon 97314

This responds to your letter of October 23, 1984 to Mr. Frank Turpin, which was forwarded ot this office for reply. You asked whether Standard No. 205, Glazing Materials, applies to travel trailers. As explained below, trailers are not covered by Standard No. 205.

Each Federal motor vehicle safety standard has an applications section which specifies the vehicles to which it applies. Standard No. 205 sets performance requirements for glazing used in a wide range of vehicles. It does not, however, apply to trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle."

Sincerely, Frank Berndt Chief Counsel

October 23, 1984

NHTSA 400 7th Street S. W. Room 5320 Washington D. C. 20590 Att'n: Francis J. Turpin

Dear Frank:

Please advise if we are correct in assuming that FMVSS apply to non-motorized vehicles as well as motor vehicles.

Specifically, is safety glazing (per FMVSS 205 and ANSI Z26) required in Travel Trailers?

Is a travel trailer, regardless of whether it is equipped with a fifth-wheel type hitch or with a tongue type hitch considered to be within the definition of a "house trailer" or "property carrying trailer?'

These questions result from an inquiry we received from a person who had purchased a new 1984 fifth-wheel travel trailer, and found it equipped with "bronze double strength window glass." The dealership who sold the trailer advised the person that safety glazing is not required.

We thank you in advance for clarifying these questions for us.

Very truly yours,

Wayne Ivie Manager, Support Section Telephone (503) 378-2057