Interpretation ID: aiam0774
Executive Vice President
Argo Plastic Company
6830 E. Washington Boulevard
Los Angeles
CA 90040;
Dear Mr. Taylor: This is in reply to your letter of June 27, 1972, requesting Federa 'approval' for plastic glazing material you manufacture. You enclose copies of certificates showing approval by the State of California.; The NHTSA does not provide approvals for glazing materials subject t its requirements. These requirements are found in Federal Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' and apply to glazing materials for use in motor vehicles manufactured for sale in the United States. (This includes the 50 States, the District of Columbia, Puerto Rico, Guam, the Virgin Islands, the Canal Zone, and American Samoa, and not 37 States as you mention.); Under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 138 *et seq.*) manufacturers must use due care to ensure that products they manufacture conform to applicable standards (15 U.S.C. 1397 (b)(2)). The manufacturer must certify conformity as specified in section 114 of the Act (15 U.S.C. 1403), and in the case of Standard No. 205, as specified in the standard. The NHTSA does not approve manufacturers' products or their certification, but monitors compliance with the standards by purchasing materials on the open market, and testing them to the requirements of the standard. The failure of materials to conform can result in the imposition of civil penalties against the manufacturer, and other sanctions (15 U.S.C. 1398, 1399).; A copy of Standard No. 205 and the National Traffic and Motor Vehicl Safety Act are enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel