Interpretation ID: 1985-02.24

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. Ralph Walker

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Ralph Walker 5517 Cleon Avenue North Hollywood, CA 91605

This responds to your letter of April 8, 1985, and follows up on your telephone conversation with Stephen Oesch of my staff concerning safety regulations applYing to sun roof windows for recreational vehicles. The National Highway Traffic Safety Administration has issued Standard No. 205, Glazing Materials, which sets requirements for the glazing used in motor vehicles, including the glazing for a sun roof in a recreational vehicle. A copy of the standard is enclosed.

You were particularly interested in the certification requirements for sun roofs. Paragraphs S6.1 and S6.3 of Safety Standard No. 205 specify that prime glazing material manufacturers shall certify each piece of glazing for use in motor vehicles. The certification must be in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act and with section 6 of the ANS Z-26 standard. These requirements would be applicable to the company from which you buy your glazing, since that company would qualify as a prime glazing material manufacturer.

As a manufacturer or distributor who cuts a section of glazing for use in a motor vehicle, your company would be required to certify its product in accordance with paragraphs S6.4 and S6.5 of Standard No. 205. S.6.4 requires your company to mark any section of glazing that it cuts with the same AS number, manufacturer model number and manufacturer trademark or designation as the piece of glazing from which it was cut.

S6.5 requires your company to certify your product in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act. Section 114 provides that an item of motor vehicle equipment (including glazing) may be certified by means of a label or tag on the item of equipment or on the outside of a container in which the equipment is delivered. The label or tag must certify that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, Standard No. 205 in this case.

Please let me know if you have any further questions.

Sincerely,

Jeffrey R. Miller Chief Counsel

Enclosure

RALPH WALKER 5517 CLEON AVE NORTH HOLLYWOOD CA 91605

Jeff Miller 5219 Room # 400 7TH St. South West Washington DC 20590

Dear Mr. Miller;

On this date I talked with Mr. Wood and he told me, I would have to write. So to get infomation on the safety codes for making sun roof windows for R.V.s. I would make them not install them.

I would appreciate the help and I will be awaiting your answer. Thank-You Ralph Walker