Interpretation ID: nht81-2.18

DATE: 04/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Weinblatt & Knee

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 5, 1981, in which you requested a copy of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials. You are apparently trying to determine what types of glazing material may be used in "caps" installed on truck bodies.

Safety Standard No. 205 specifies performance requirements for glazing materials to be used in motor vehicles and motor vehicle equipment. The standard incorporates by reference the American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways," Z26.1-1966 (ANS Z26). Copies of both standards are enclosed. ANS Z26 and Standard No. 205 list 13 "Items" or types of glazing that vary in terms of the performance tests each item must pass and the locations in which each type of glazing may be used. While the meaning of the word "cap" as used in your letter is somewhat unclear, we presume you are referring to a "pickup cover." A "pickup cover" is defined in paragraph S4 of Standard No. 205 as a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user. All 13 items of glazing may be used in pickup covers. However, some items (e.g., Item 6) may not be used in forward-facing windows, and others (e.g., Item 5) may not be used at levels requisite for driving visibility.

Certification and marking requirements for glazing are found in paragraphs S6.4 and S6.5 of Standard No. 205.

We hope you find this information helpful. Please contact this office if you have any further questions.

Sincerely,

ATTACH.

March 5, 1981

U.S. Department of Transportation -- Attn: Regulatory Division

Gentlemen:

I have been informed by a client that there is a Federal regulation promulgated by your Department requiring a certain safety stamping with a number of every peice of glass or plastic substitute for glass used on any auto, truck, camper, cap, etc.

I would greatly appreciate a copy of that regulation since it involved a legal question as to what my client is allowed to install as part of his business of selling caps that go on truck bodies.

Thank you for your immediate attention in this matter.

Very truly yours,

SEYMOUR S. WEINBLATT -- WEINBLATT & KNEE COUNSELLORS AT LAW