Interpretation ID: nht81-1.11

DATE: 02/09/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Synnestvedt & Lechner

TITLE: FMVSS INTERPRETATION

TEXT: This replies to your letter of December 11, 1980, in which you ask us to reconsider the interpretation we issued on April 22, 1980, regarding Safety Standard No. 205, Glazing Materials. We stated in our letter to you on that date that the abrasion test for vehicle windshield glazing must be conducted on both the exterior and the interior surfaces of the windshield (i.e., both surfaces must comply with the requirements of the standard).

After further consideration, we reaffirm our earlier interpretation. However, on January 19, 1981, the NHTSA did issue an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on whether Standard No. 205 should be amended to adopt less stringent requirements for glass-plastic glazing. A copy of that notice is enclosed for your information.

Please contact this office if you have any more questions.

Sincerely,

ATTACH.

SYNNESTVEDT & LECHNER

December 11, 1980

Frank E. Berndt, Esquire -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Re: NOA-30

Dear Mr. Berndt:

By letter of December 9, 1980 from Mr. Michael M. Finkelstein, we have been advised of the granting of the petition of our client, Saint-Gobain Vitrage, to amend Federal Motor Vehicle Safety Standard No. 205.

In the context of a rulemaking proceeding in progress, we ask that prompt attention be given to our letter of May 7, 1980, copy enclosed, requesting that you reconsider the interpretative ruling we seek. By the interpretation we urge, some actual on-road experience in the United States could be gathered during the pendency of the rulemaking proceeding. This would come about through the supply from Saint-Gobain Vitrage to European car manufacturers who are already customers for the Securiflex inner guard windshield, of additional such windshields to be used in cars being shipped to the United States. Audi and Peugeot are obvious candidates to begin such introduction, although there are other European car manufacturers who would probably do the same, perhaps as an optional feature.

We will look for your response.

Very truly yours,

John T. Synnestvedt

Enclosures

cc: Joan Claybrook