Interpretation ID: 571.205--Low Speed Windshield Clarification --Burgess

October 28, 2022

Mr. Dave Burgess
Burgess Consulting
Unit 6, Benford Court
Warwick CV34 5DA
United Kingdom

Dear Mr. Burgess,

I write in response to your email to the National Highway Traffic Safety Administration (NHTSA) asking about federal requirements for windshields in low-speed vehicles (LSVs). Please note that our answer below is based on our understanding of the specific information provided in your initial and subsequent email correspondence.

Background

NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue Federal Motor Vehicle Safety Standards (FMVSS) that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects.

Your email correspondence, dated June 17, 2022, laid out several questions relating to LSVs and FMVSS 500, including: (1) whether LSVs must be fitted with a windshield; (2) if fitted with a windshield, whether LSVs must comply with 49 Code of Federal Regulations (CFR)

§ 571.500; and (3) if a fitted windshield is required, what, if any, are the size and position requirements for the windshield?

In response, on July 25, 2022, NHTSA asked via email for further clarification on the number of wheels and maximum capable speed for the specific vehicle referenced in your correspondence. You provided written confirmation to NHTSA that the vehicle at issue has four wheels, is capable of a maximum speed of no more than 25 miles per hour, and subsequently confirmed that the vehicle has a gross vehicle weight rating (GVWR) that is less than 1,361 kilograms (3,000 pounds).

Discussion

49 CFR § 571.3 defines an LSV as a motor vehicle that: (1) is four wheeled; (2) has a speed attainable in 1.6 kilometers (1 mile)1 that is more than 32 kilometers per hour (20 miles per hour) and not more than 40 kilometers per hour (25 miles per hour) on a paved level surface; and (3) has a GVWR that is less than 1,361 kilograms (3,000 pounds). A vehicle must meet all three criteria to qualify as an LSV.

A vehicle that meets the definition of an LSV must be manufactured to conform to 49 CFR § 571.500, which, among other things, requires LSVs to be equipped with a windshield that conforms to paragraph S5.4 of FMVSS No. 205 on glazing materials. Specifically, FMVSS No. 205 applies to glazing installed in motor vehicles prior to first purchase and also to aftermarket glazing for use in motor vehicles. The standard incorporates by reference an industry standard, the “American National Standards Institute American National Standard for Safety Glazing Materials for Glazing Motor Vehicles and Motor Vehicle Equipment Operating on Land Highways-Safety Standard” (ANSI/SAE Z26.1-1996). FMVSS 205 S5.4 specifically notes that windshields of LSVs must meet the ANSI/SAE Z26.1-1996 specifications for either AS-1 or AS-4 glazing.

In summary, if a vehicle qualifies as an LSV under the definition laid out in 49 CFR § 571.3, it must meet the requirements outlined in 49 CFR § 571.500, which include a windshield that conforms to paragraph S5.4 of FMVSS No. 205. Specifically, LSV windshields must meet the ANSI/SAE Z26.1-1996 specifications for either AS-1 or AS-4 glazing. No specific federal requirements exist concerning the size or position of windshields for LSVs.

I hope this information is helpful. If you have any further questions, please feel free to contact Natasha Reed of my staff at this address or at (202) 366-2992.

Sincerely,

John Donaldson
Acting Chief Counsel

Dated: 10/28/22

Ref: FMVSS No. 205

1 See 49 CFR 571.500 S7. Test Procedure, stating that “[e]ach vehicle must meet the performance limit specified in S5(a) under the following test procedure. The maximum speed performance is determined by measuring the maximum attainable vehicle speed at any point in a distance of 1.6 km (1.0 mile) from a standing start and repeated in the opposite direction within 30 minutes.”