Interpretation ID: nht72-3.19

DATE: 01/13/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Libbey-Owens-Ford Company

TITLE: FMVSS INTERPRETATION

TEXT: You have requested that Libbey-Owens-Ford Company be exempted from the requirements of Part 566. Your request is denied for the reasons set forth below.

You state that Libbey-Owens-Ford is a manufacturer of automotive safety glass which has been assigned a DOT number under the "certification alternative" of Standard No. 203. You draw an analogy to the exemption of tire manufacturers from the manufacturer identification regulation, based on your (Illegible Word) under other NHTSA regulations to submit (Illegible Words) meets the requirements of Part 566.

However, the analogy is incorrect in that manufacturers of glassing materials are not specifically required by Standard 205 to submit the data required by Part 566. If manufacturers meet the certification requirements of $ 114 of the Act, no admittal of information is required. If they do choose the certification alternative, as Libbey-Owens-Ford has done, it is still not clear that the requirements of Part 566 will be met.

By contract, under Part 574 submittal of information is (Illegible Word) for all covered tire manufacturers. Moreover, that regulation in its "Identification mark" occasion requires submittal of specific information which has been found to meet the requirements of Part 566.

The purpose of Part 566 is to establish a centrally organized system to collect information regarding the manufacturer's corporate status, mailing address, and items manufactured. Such a system has been found necessary for efficient enforcement of the Act as well as distribution of information to manufacturers. These purposes cannot be accomplished if individual manufacturers in particular industries are greater exemption from coverage.