Interpretation ID: nht73-1.41

DATE: 06/28/73

FROM: Richard B. Dyson; NHTSA

TO: Transportation Sash Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 21, 1973, requesting that we clarify the certification and marking requirements for glazing materials. You indicate that you purchase block size glass and cut it to suit your customers.

The requirements to which you refer are found in Federal Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR @571.205). They require each item of glazing material to be labeled with certain information, that specified in section [Illegible Number] of ANS @26.1-1966, which includes the manufacturer's trademark, the symbol AS or the words American Standard, a model number, and a reference, in the form of a number, that indicates the type of glazing material. All glazing materials for use in motor vehicles must be labeled with this information, which can be stencilled onto the material if it is removed during the cutting process.

In addition to these identifying markings, each item of glazing material must be certified as conforming to the Federal standard. Prime glazing material manufacturers (those who fabricate, laminate, or temper the glazing material) certify glazing that is designed for use in any specific vehicle by including with the above markings the symbol DOT and a code number assigned to the manufacturer by this agency. Glazing that is not designed for a specific vehicle is certified pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), which includes, as you indicate, the use of a label or tag affixed to the glazing material that states that the material conforms to all applicable Federal motor vehicle safety standards. Manufacturers other than prime glazing material manufacturers, such as those, like yourself, who cut larger sheets to size, are required to certify in the same fashion; that is, in accordance with section 114, and may certify by labels or tags affixed to the material.

I have enclosed a copy of the marking requirements of Standard No. 205 for your information. If you wish to obtain a copy of the American National Standard @@26.1-1966, you should write to the American National Standards Institute, 1430 Broadway, New York, New York 10018.