Interpretation ID: nht78-3.9

DATE: 03/08/78

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: O'Sullivan Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 3, 1978, to Mr. Guy Hunter of my staff, requesting assignment of a "DOT" code number for purposes of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. You state that you supply vinyl plastic sheeting to your customer who, in turn, laminates and polishes this sheeting for use as glazing in the rear window opening of convertibles.

Under paragraph S6 of FMVSS No. 205 (a copy was previously mailed to you), the assignment of a code number is restricted to prime glazing material manufacturers. Prime glazing material manufacturers are those who either fabricate, laminate, or temper the glazing material. Since you merely supply the material to your customer who then laminates and polishes it for use as glazing, you are not considered the prime manufacturer and assignment of a code number to you is not appropriate. Your customer is the prime manufacturer in this case and it is his responsibility to certify that his glazing meets the requirements by the means specified in FMVSS No. 205.

If I can be of further help, do not hesitate to contact me.

Sincerely,

ATTACH.

O'Sullivan Corporation

February 3, 1978

Guy Hunter -- NATIONAL HIGHWAY & TRAFFIC SAFETY ADMINISTRATION

Dear Mr. Hunter:

We used to calender clear vinyl plastic sheeting which was subsequently laminated and polished and used in the automobile rear windows.

Our former customer recently ordered another quantity of this plastic. We understand that suppliers of this type of materials must obtain a D.O.T. number and we would appreciate having one assigned to us.

Yours very truly,

R. C. Evans, Vice President Director of Research & Development

cc: J. S. Campbell; C. R. Creamer; N. R. Hamblin