Interpretation ID: aiam3818
Sheeskin
Hillman & Lazar
P.C.
6110 Executive Boulevard
P.O. Box 2186
Rockville
MD 20852;
RE: your file 3189/001:11 Dear Mr. Sheeskin: This responds to your letter of March 7, 1984, concerning discussion between your client and the Maryland State Police about the application of tinting or sun screening materials to vehicle glazing materials. This office has sent two letters of interpretation concerning the application of glazing materials to the Maryland State Police. I am enclosing a copy of the agency's letters of December 20, 1983 and April 3, 1984 and the Maryland States Police's original request for an interpretation.; As stated in our letter of April 3, 1984, the application of tintin materials to glazing does not, in and of itself, constitute a violation of the render inoperative provisions of section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. To violate section 108(a)(2)(A), manufacturers, distributors, dealers, and motor vehicle repair shops that install tinting materials must knowingly install materials which render inoperative the glazing material's compliance with Standard No. 205. Thus, for example, a motor vehicle repair shop would be in violation of section 108(a)(2)(A) if it knowingly installed on a passenger car's window a tinting material which would render inoperative the glazing's compliance with the abrasion resistance or luminous transmittance requirements of the standard.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel