Interpretation ID: 11385-1.PJA
QA Manager
AP Technoglass Co.
1 Auto Glass Drive
P.O. Box 5000
Elizabethtown, Kentucky 42702-5000
Dear Mr. Taul:
This responds to your requests for two interpretations regarding printing a label and an antenna on vehicle glazing. I apologize for the delay in responding. The short answer to your questions is that you may not emboss or otherwise affix these items to any window, unless a light transmittance requirement is met.
Your first letter requests information on whether you may print a one inch by two and a half inch anti-theft label directly on the glass near the bottom of the driver=s side window. The manufacturer is currently applying stick-on labels to accomplish this but wants to start using a black ceramic material. Your second letter asks a similar question, whether an antenna could be printed in silver on a quarter window behind the C-pillar of a Saturn station wagon. You reason that this should be allowed because antenna and heat lines are allowed in the rear window, which is used more than the quarter window for driver visibility. However, you acknowledge that your proposed antenna lines are thicker than most rear window lines.
In both letters, you enclosed illustrations with proposed locations for these items and ask, if the items were not allowed in the proposed locations, if there were any alternative
locations where the label or antenna would be allowed. As a final alternative, each letter proposes marking the glazing with an arrow indicating that the area of the window containing the item is not intended to meet the light transmittance requirements.
Federal Motor Vehicle Safety Standard No. 205, Glazing materials, has a light transmittance requirement of 70 percent that applies to all windows Arequisite for driving visibility.@ Z26 section 4.2, Footnote 1. This agency has a longstanding interpretation that all windows in passenger vehicles are requisite for driving visibility. Therefore, both the driver=s side window and the rear quarter window behind the C-pillar would both have to meet the requirements.
NHTSA presumes that all areas of the window are requisite for driving visibility and have to meet the transmittance requirements. NHTSA has in the past excluded some portions of the windshield based on the fact that they are not required for driving visibility. For example, in the November 3, 1988 letter to Volkswagen of America that Paul Atelsek of my staff sent you, we determined that it would be permissible to apply ceramic dots in a shade band along the bottom of the windshield only in those portions through which the shortest driver sees the hood or other parts of the vehicle he or she is driving, because seeing these parts of the vehicle is not requisite for driving visibility. We have also determined that sunroofs and the shade band at the top of the windshield are not necessary for driving visibility. NHTSA is not aware of any other areas of windows that the driver could see through that are not requisite for driving visibility.
You have not established that the portion of the driver=s side window to which you propose to affix the anti-theft label would provide the shortest driver with a view only of his or her own vehicle. Therefore, the presumption is that that portion of the driver=s side window would have to meet the transmittance requirements. You have also not shown that the rear quarter window behind the C-pillar, to which you propose to affix the antenna, would provide such a view, so the same conclusion applies.
Without conducting a test, we cannot tell you whether your proposed label or antenna would cause the glazing to fail test number 2 of Z26. We note that the transmittance requirements apply even to stick on labels that are not readily removable by hand. However, if the glazing did meet the test, as well as all the other required tests, then there is nothing in the standard to prevent you from printing the label or antenna directly on the glazing.
Regarding your question of whether the label would be permitted on any other window glass, the answer is that the same considerations apply to the other windows you mentioned (i.e., front door glass, rear door glass, rear quarter door glass window, or rear window glass). The requirement to be able to see adequately through the window is not diminished, as your second letter suggested, merely because the rear quarter window is less used for driving visibility than some other window.
Regarding your suggestion that you could merely mark the glass with an arrow to indicate that the portion of the window encompassing the label is not intended to meet the transmittance requirements, that would not be permitted. Section 6 of Z26 merely explains marking requirements, and does not by itself exempt portions of the glazing from having to meet requirements defined elsewhere. This provision was added to the marking requirements to clearly delineate, prior to testing, the shade bands that Z26 permits at the upper edge of the windshield. To allow a vehicle manufacturer to do this in other areas would be tantamount to eviscerating the transmittance requirement. For example, a manufacturer could mark the windows such that all of the window, except perhaps for a thin strip at the top, was designated as not intended to meet the requirement.
You asked about the mention in the November 3, 1988 letter of a rulemaking action the agency intended to initiate to better define what areas are Arequisite for driving visibility.@ NHTSA did not initiate such a rulemaking action and currently has no plans to do so.
I hope this information is helpful. If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Samuel J. Dubbin Chief Counsel ref:205 d:5/1/96
You are referring to a paragraph in the marking requirements in section 6 of ANSI Z-26.1-1977 (Z26), incorporated by reference in Standard No. 205, that states AGlazing materials, which in a single sheet of material are intentionally made with an area having a luminous transmittance of not less than 70% (Test No. 2), adjoining an area that has less than 70% luminous transmittance, shall be permanently marked at the edge of the sheet to show the limits of the area that is intended to comply with Test No. 2.@ The area is to be marked with an arrow indicating the part of the sheet that complies.