Interpretation ID: nht70-2.15

DATE: 06/29/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Cristales Inastillables de Mexico S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1970, requesting the National Highway Safety Bureau's approval or comments on an Electrical Testing Laboratories Report No. 411430, concerning your CM-20 safety glazing material. The National Highway Safety Bureau does not approve or confirm whether specific motor vehicles or items of motor vehicle equipment comply with Federal standards. Under the National Traffic and Motor Vehicle Safety Act, the manufacturer of a motor vehicle or item of motor vehicle equipment bears the responsibility for ensuring that his product complies with applicable standards. Section 114 of the Act (15 U.S.C. @ 1402), furthermore, requires manufacturers to "certify" that their products comply with applicable standards, and specifies how this certification is to be accomplished. A notice published in the Federal Register on November 4, 1967, further explained how manufacturers of motor vehicle equipment may comply with this requirement. I enclose a copy of this notice and the aforementioned Act, with the appropriate sections marked for your information.

Federal Motor Vehicle Safety Standard No. 203 (S3.4) provides an additional method by which manufacturers of glazing materials for use in motor vehicles may certify that their products comply with that standard. This method may be used as a substitute for the methods specified in section 114 and the enclosed notice. It consists of labeling the glazing material with a label that meets the requirements of Section 6 of ASA Z.26.1-1966, "Marking of Safety Glazing Materials", but to which has been added the symbol "DOT", and a manufacturer's code number which assigned by the Bureau on request. The label which you furnish in the appendix to your ETL

Report No. 411430, provided the required "AS"-designation, glazing-model number, and assigned DOT code mark are at least 0.070 inch in height, will meet this requirement. Should you desire to certify your glazing in this manner, we will furnish you with a manufacturer's code number.

Although the Bureau does not furnish approvals of glazing materials, many states do require some form of approval before specific glazing material can be used in motor vehicles subject to their jurisdiction. For information regarding such approvals and assistance in obtaining them I suggest you write to the American Association of Motor Vehicle Administrators, Attention: Mr. Armand Cardarelli, Suite 500, 1828 L Streets N.W., Washington, D.C. 20036.

In addition, as a manufacturer of motor vehicle equipment for importation into the United States, you are required by section 110(e) of the Act (15 U.S.C. @ 1399(a)) to designate an agent for service of process purposes. The designation must conform to regulations governing its making (49 CFR 551.45), and I enclose a copy also with appropriate sections marked for your reference.