Interpretation ID: nht71-1.20
DATE: 06/26/71
FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA
TO: D.C. Transit System, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of June 15, 1971, to Mr. Roy J. Dennison, concerning the use of Abcite coated acrylics in side windows of D.C. Transit buses.
Standard No. 205, Glazing Materials-Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses presently allows the use of AS-4 or AS-5 rigid plastics in the side wiodows of buses when the side windows are readily removable. Readily removable windows are defined in ANSX Standards ZZ6.1-1966 as "windows that can be quickly and completely removed from the motor vehicle without tools."
If this provision of the Standard is not adequate to satisfy your needs, we will be pleased to meet with you to discuss the matter further.
Office of the General Counsel D.C. Transit System. Inc.
June 15, 1971
Roy A. Dennison,
Safety Standards Engineer
Code 41-42
National Highway Traffic Safety Administration
Dear Mr. Dennison:
Pursuant to our conversations regarding the use of acrylic coated with Aboite, I enclose herewith for your consideration two letters from the Dupont Company relative to certain tests made.
I wish to request that you give this matter your prompt consideration for the reason that this organization would like to be able to use this material in certain new buses that it intends to order as part of its fleet together with the use of same in windows on our used buses. I am arranging for a sample of the material to be sent to you under separate cover.
What we hope to obtain from you is a statement to the effect that the material does meet the safety standards of your department and in turn this would allow us to take this matter up with the District of Columbia authorities in order to be able to use this material as windows in our fleet.
I will await your reply after your investigation of this matter.
Very truly yours,
May 28, 1971
R. Dennison, Office of Crash Injury Reduction, U.S. Department of Transportation, Federal Highway Administration, National Highway Safety Bureau,
Dear Mr. Dennison,
I have been having difficulty trying to contact you over the last two weeks, probably because of your vacation, but hope that you can give me a very quick answer to two questions arising out of the proposed modifications to Standard 205.
The first question concerns the date when the marking modifications become effective. My own reading of the Standard is that, since it is a Standard for glazing materials, then the effective date applies to the manufacture of the glazing material and not to the fitting of the glazing material into the automobile. If I am wrong in my assumption, then we have to bring our whole modification process very much more forward, because a glass to be, fitted in January must have been made by September, because of the large number of glasses already in the pipe line.
The second problem concerns the actual form in which the DOT certification appears. Triplex has been allocated symbol DOT 17 and that is the symbol which we put on the glass. The proposed modification to 205 calls for a hyphen to be placed between DOT and the number (17 in our case). Will you accept the marking DOT 17 without the hyphen, because all our stencils and master plates have been made in this form and we should be put to both considerable expense and delay in getting all the master plates modified.
I am sending a copy of this letter to Mr. Clue to Mr. D. Ferguson in case you are still on vacation, as I am urgently needing advice.
With kind regards,
Yours sincerely,
A. J. HOLLAND--TRIPLEX SAFETY GLASS CO. LTD.
E. I. Du Pont De Nemours & Company
PLASTICS DEPARTMENT
May 7, 1971
H. T. Smyth
Vice President Purchasing - Contracts
D. C. Transit System, Inc.
Dear Mr. Smyth:
In your letter of March 25, 1971, you asked me to certify to the following:
Du Pont Abcite abrasion resistant sheet - acrylic satisfies the requirements of Items 4, 5, 6 and 7 of the ASA Safety Code for Safety Glazing Materials for glazing motor vehicles operating on land highways - Z26.1 - 1966.
I am pleased to advise that our tests and investigations are now completed to an extent where we certify our material (Abcite abrasion resistant sheet - acrylic) does meet all of the ASA Z26.1 - 1966 requirements for the above items.
I hope this certification is in time for you to specify Abcite for your new coaches, and you will now proceed with additional usage on your current fleet.
If you have questions or need additional information, please contact me.
Sincerely,
Russell H. Berry, Jr.--
Development Specialist
Abcite Venture
E. I. Du Pont De Nemours & Company
PLASTICS DEPARTMENT
March 29, 1971
H. T. Smyth
Vice President, Purchasing - Contracts
D. C. Transit System, Inc.
Dear Mr. Smyth:
Thank you for your letter of March 25, and we are pleased to hear of the satisfactory results of your tests with windows of acrylic coated with Abcite (Registered). Your decision to convert your fleet to Abcite (Registered) pending governmental approval is also exciting news.
You asked for a letter "stating that this material satisfies the requirements of: Items 4, 5, 6 & 7 of the ASA Safety Code for Safety Glazing Materials for glazing motor vehicles operating on land highways - Z26.1 - 1966".
All our data indicate that acrylic coated with Abcite (Registered) abrasion resistant coating satisfies all of the requirements in the above items of the ASA Code. We are submitting sample material to an outside testing laboratory for certification to verify our data. Tests run by an independent testing laboratory at the request of the Department of Transportation show a non-compliance in the weathering tests with which we seriously disagree. All our weathering data, both in lab tests and outside weathering tests, show essentially no change in optical quality, light transmission and haze levels. (See Page 3 of attached product bulletin.) However, as I stated, we are having these tests run at our request for certification.
I hope the above satisfies your requirements but if there are any questions or if you need additional information, please contact me. My telephone number is 302//4-4639.
Sincerely,
Russell H. Berry, Jr. --
Development Specialist
Abcite (Registered) Venture
Enclosure