Interpretation ID: 1985-02.1

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Jim Preisler -- Senior Vice President, Drag Specialties

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Jim Preisler Senior Vice President Drag Specialties P.O. Box 9336 Minneapolis, MN 55440

This responds to your letter of January 17, 1985, concerning Standard No. 205, Glazing Materials. Your company manufactures an aftermarket replacement motorcycle windscreen, which incorporates auxiliary wind deflectors. Standard No. 205 specifies that the upper portion of the windshield can be made out of item 1, 6, 10, or 11 glazing materials. The glazing used in the auxiliary wind deflectors can be made out of item 1, 2, 4, 10, or 11A glazing materials. You said that the glazing material used in the windscreen and deflector meets the requirements for both item 4 and 6 glazing materials. You asked whether you can mark both those components as item 4/6 glazing materials. The answer is that you can mark them as item 4/6 materials.

Section S6 of the standard sets out the certification and marking requirements for each item of glazing material. It provides that each piece of glazing material shall be marked, in accordance with section 6 of American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways" Z-26.1 - 1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980, with a number signifying that it meets the performance requirement set for that particular glazing item number. In your case, the glazing material meets all for the requirements set for two separate item numbers. Since your product conforms to the requirements for both items 4 and 6 the agency has no objection to marking the components with both item numbers.

Sincerely,

Jeffrey R. Miller Chief Counsel

National Highway Traffic Safety Administration Room 5219 400 7th St. S.W. Washington, D.C. 20590 Mr. Frank Berndt, Chief of Council January 17, 1985

Dear Mr. Berndt:

I was referred to your office by Mr. Steven Oesch for assistance with my request.

My company is manufacturing an aftermarket replacement motorcycle windscreen. We applied for and were assigned manufacturer's code number 353, as specified in FMVSS No. 205. The material of the windscreen must meet Item #6 of the American National Standard Z26.1 1983. Our windscreen incorporates auxiliary wind deflectors (2) as part of its design. The deflector material must meet Item #4 of the same standard.

The material we are specifying for the windscreen and the deflectors meets both Items #4 and #6. I am requesting permission to mark both devices as 4/6. The reason for my request is based on cost savings. Each hot stamp die to mark the devices can be $500 to $1000 each.

Please advise me as soon as possible as our production date is closing in on us.

Sincerely,

Jim Preisler Senior Vice President