Interpretation ID: aiam4326
The Sentinel Group
P. O. Box 905
Miami
FL 33137-0905;
Thank you for your letter to Stephen Oesch of my staff concernin Standard No. 205, *Glazing Materials*. I regret the delay in our response. You explained that your company represents, on an exclusive basis, a number of different manufacturers of both windshields and tempered glazing material for automobiles. You asked whether it is possible to consolidate these different manufacturers 'into one identity by using both one DOT number assigned to the Sentinel group as well as one university logo.' As explained below, the answer is yes with regard to using one logo, but no with regard to using one DOT certification number.; S6 of Standard 205 specifies certification and marking requirements fo manufacturers and distributors of glazing material for use in motor vehicle and motor vehicle equipment. All glazing material must be marked both with the basic identifying information specified in section 6 of the ANSI standard Z26.1 (as modified by S6.1 of Standard 205) and with a certification that the glazing meets the requirements of all applicable Federal motor vehicle safety standards. Different certifications are specified for prime manufacturers and other manufacturers/distributors of glazing material (contained in paragraphs S6.2 through S6.5 of the standard).; Further distinction in certification requirements of prim manufacturers depends on whether the glazing is designed for use in a specific motor vehicle or camper, or whether the glazing is designed to be cut into components for use in motor vehicles or items of motor vehicle equipment. (A prime manufacturer is defined in S6.1 of the Standard as one who fabricates, laminates or tempers the glazing materials, as opposed to one who alters or cuts an already manufactured piece of glazing.); Since you indicate in your letter that the manufacturers you represen make windshields and tempered glazing materials for automobiles, we assume that the glazing is manufactured by the prime manufacturer and is designed for use in a specific motor vehicle or camper. In this case,the S6.2 certification requirements apply, which include marking each piece of glazing material with the symbol DOT and a manufacture's code mark, assigned by NHTSA.; The purpose of the manufacturer's code mark is to aid the agency i identifying the actual manufacturer of the glazing for the purpose of defect and noncompliance recall campaigns. Accordingly, the agency only issues a code mark to a manufacturer that actually fabricates, laminates or tempers glazing materials. We have found the code mark to be an effective method to identify the manufacturer for enforcement purposes.; Because of this, the agency is less concerned that the distinctive log be for the same company as that which the code mark indicates. For example, in a November 7, 1983, letter to the Libby-Owens-Ford Company, the agency stated that so long as the manufacturer placed its DOT code mark on the glazing material, the tracing and enforcement policies would not be circumvented and the use of another company's logo would not violate Standard No. 205. Accordingly, it is acceptable, if you wish to have each prime manufacturer mark its glazing material with its unique code mark and your logo for the Sentinel group, which is used for all of the various manufacturers you represent.; I hope this provides an adequate response to your question. Sincerely, Erika Z. Jones, Chief Counsel