Interpretation ID: aiam4269
Product Performance Specialist
General Electric Company
One Plastic Avenue
Pittsfield
MA 01201;
Dear Mr. Torrey: Thank you for your letters of August 13, and 26, 1986, concerning ho the requirements of Standard No. 205, *Glazing Materials*, apply to glazing materials installed in the side windows of some New York City Transit Authority (NYCTA) buses. As explained below, the information you provided in your letters and in your phone conversations with Stephen Oesch of my staff and the information provided by NYCTA in a June 19, 1986 letter to the agency indicates the glazing materials installed in the NYCTA buses do not comply with the marking requirements of the standard.; You explained in your letter that the glazing material used in the sid and standee windows in the buses is Lexan sheet, which is a plastic material manufactured by General Electric. According to your letter the Lexan glazing material used in these windows can meet all of the performance requirements set in Standard No. 205 for 'AS-5' glazing materials. However, the material apparently was not marked as 'AS-5' material, but may have instead been marked 'AS-4/6.' (Information provided to the agency by the NYCTA in June 1986 indicates that the windows did not contain any 'AS' number. At the time of your phone conversation with Mr. Oesch, you had not been able to confirm what markings, if any, had been placed on the glazing material by General Electric).; Standard No. 205 specifies performance and location requirement fo glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as 'items' in the standard). Plastic glazing materials, such as Lexan, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set AS-5 glazing materials, it can be used in any window in a bus, except for the windshield, windows to the immediate right and left of the driver and the rearmost windows if used for driving visibility.; In addition to setting performance requirements for different items o glazing, the standard requires glazing materials to contain certain markings. The marking requirements of S6 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked with the AS number (which indicates that the material meets the performance requirements set for that 'item' of glazing material), a model number and the manufacturer's logo. The information the agency has received about the markings on the glazing installed in the NYCTA buses indicates that the glazing does not have an AS number marked on it.; Any glazing sold for use in a motor vehicle must conform to th applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, General Electric is required by Part 575 of our regulations to file a report with the agency providing additional details about the noncompliance and General Electric's plans to remedy the noncompliance. As you requested Mr. Oesch, I am also enclosing a copy of the agency's regulation concerning the filing of a petition for a determination that a noncompliance is inconsequential.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel