Interpretation ID: nht74-2.35

DATE: 07/30/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Excel Industries

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 28, 1974, requesting the status of a proposed amendment published January 9, 1971 (36 F.R. 327), to Motor Vehicle Safety Standard No. 205, "Glazing Materials," that would have required markings specified for windshields to appear in each windshield's lower left-hand corner.

This proposed requirement was not adopted. Other requirements proposed by this notice, however, were adopted by a subsequent notice published June 21, 1972 (37 F.R. 12237), which amended Standard No. 205. The preamble of this notice referred to the agency's action on the proposed requirements for marking location. A further notice was issued on November 11, 1972 (37 F.R. 24035), which responded to petitions for reconsideration of the amendments of June 21, 1972. Copies of the notices of June 21 and November 11, 1972, are enclosed.

There are presently no requirements regarding the location of markings for motor vehicle glazing materials.

Yours truly,

ATTACH.

June 28, 1974

Lawrence Schneider -- National Highway Traffic

Safety Administration

Dear Mr. Schneider:

On January 9, 1971, page 327 of volume 36, #6 of the Federal Register, a proposed amendment was made to FMVSS#205 at the request of the California Highway Patrol to the effect that after installation of the glazing material in the vehicle, the markings are required to be visible in the lower left corner of each windshield and either the lower left or lower right corner of any other window.

As a manufacturer of windshields and side windows for the recreational vehicle industry, particularly motor homes, we have been trying to comply with this proposed standard by adding two trade marks to our windshields so that in a two part windshield, the glass could be used on either side of the vehicle and still comply; however, in reviewing the Federal Register, we find that no follow-up amendments to the safety standard reflect this change.

With the cost of materials increasing daily, and the fact that we are paying a premium for this added marking, we are going to discontinue this practice since Mr. Douglas Delve of the Department of Transportation has confirmed that this legislation has never been effected. I would like a written confirmation that this pending legislation is either still pending or has been dropped, so that we may proceed with production without any further concern regarding the compliance to the standards.

Very truly yours,

Steve A. Spretnjak -- Chief Design Engineer EXCEL INDUSTRIES