Interpretation ID: aiam3527
Director
Consumer and Technical Affairs
Woodhill Permatex
18731 Cranwood Parkway
Cleveland
OH 44128;
Dear Mr. Carter: This responds to your recent letter concerning a product yo manufacture which is used to repair breaks in automobile windshields. You ask whether such a repair product would conflict with any present motor vehicle safety standards.; The National Highway Traffic Safety Administration has issued Federa Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair product such as you describe, however. There is no Federal regulation which would prohibit the use of such a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new windshield which may require repair as a result of damage sustained, for example, in shipment could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, which would be the responsibility of the person selling the windshield. Therefore, we do not recommend use of windshield repair kits prior to the first purchase of a new windshield by a consumer.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel