Interpretation ID: aiam0747
Vice President
Manufacturing--Window Division
4801 Springfield Street
Dayton
OH 45401;
Dear Mr. Sanders: This is in reply to your letter of June 1, 1972, requesting a interpretation as to the application of Federal Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' to certain recreational vehicles and equipment, pictures of which you enclosed. These components consist of slide-in and chassis-mount campers, trailers, and motor homes.; In a recently issued amendment to Standard No. 205, the NHTSA ha clarified the application of the standard to campers. As amended, the standard applies to campers, both slide-in and chassis-mount, that are designed to transport occupants while in motion. Accordingly, the pick-up cap which you illustrate appears to be exempt from the standard. In addition Standard No. 205 does not apply to trailers, and would not apply to the fifth-wheel unit illustrated in the drawing forwarded to us.; With reference to the chassis-mount and slide-in campers, any windo except forward facing windows, which include both front-facing windows and behind-the-cab windows, may be manufactured of any glazing material (AS 1 through AS 11) specified in ANS Z26.1-1966, and two additional materials (Items 12 and 13), the requirements for which are specified in the recent amendment. With reference to forward-facing camper windows, all of the above materials may be used, except for AS 6 and AS 7 glazing materials, as specified in ANS Z26.1-1966, and item 13 glazing specified in the new amendment.; With respect to motor homes that are not campers, these vehicles ar multipurpose passenger vehicles and must meet the glazing requirements for trucks. Accordingly, the windshield must be manufactured of either AS 1 or AS 10 glazing materials, side windows to the immediate right or left of the driver must be either AS 1, AS 2, AS 10, or AS 11 materials, and other side windows must be either AS 1, AS 2, AS 3, AS 4, AS 5, AS 8, AS 9, AS 10, or AS 11 glazing materials. We would consider the overhead window in the motor home you illustrate to be an 'opening in the roof,' and any of the materials allowed in side windows, or the materials allowed to be used by the recent amendment, may be used in this location.; Yours truly, Richard B. Dyson, Assistant Chief Counsel