Interpretation ID: nht91-6.1

DATE: September 17, 1991

FROM: Herbert J. Lushan -- Regalite Plastics Corp.

TO: Paul Jackson Rice -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 11-20-91 from Paul Jackson Rice to Herbert J. Lushan (A38; Std. 205)

TEXT:

I am writing you at the suggestion of John Rigby.

Regalite Plastic is a manufacturer of Clear Flexible Plastic Sheets that are used in the rear windows of Convertible automobiles and as side and rear windows of Jeep-type vehicles.

Our regular clear ULTRALITE window meets and exceeds the ANSI Z26.1-1977 Item 6 test requirements.

We have been asked by one of our customers to make a bronze TINTED clear plastic flexible window for the rear and rear sides of their Jeep-type vehicle. This bronze tinted clear will not pass Test #2, Luminous Transmittance Test.

Since these Jeep-type vehicles are considered MPV (Multi purpose vehicles) by the manufacturer, I understand that they only have to meet the Item 7 SPECS which eliminates the Test #2 for Luminous Transmittance as a requirement.

Please confirm or deny whether my understanding or interpretation is correct so that we may proceed properly.