Interpretation ID: nht93-5.32

TYPE: Interpretation-NHTSA

DATE: July 22, 1993

FROM: Richard Campfield -- President, Ultra B-O-N-D, Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA; Marvin Shaw -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10/26/93 from John Womack to Richard Campfield (A41; Std. 205)

TEXT:

Quite a few months back you had been quite helpful in sending information to me concerning regulations on Windshield Repair. It was noted that there is no Federal regulation which prohibits the use of a product or process in the repair of a windshield which has previously been installed in a vehicle and damaged in use. We have some conflicts that are occurring in the industry which we are hoping you can assist us with or direct us to the individual(s) who may aid us with this unfair dilemma.

In May of this year, a meeting was held by the National Glass Association which had formed a committee to set "Standards" for Windshield Repair. Let me first share that this committee was comprised (100%) of individuals specializing in REPLACEMENT. Parties opposing the meeting were given very short notice of its taking place and in fact our office received papers relevant to the meeting one day prior to the actual meeting. In any event, it is clear that the Windshield Repair Industry has made a cut in the replacement industry and these individuals are trying to put the favor back in their hands.

In any event, the standard they are trying to set is based on one used in Australia (not a law) and sets limitations that are unfounded and lack any justification whatsoever for these actions. I'll outline them as briefly as possible. (There are currently many repair technicians in Australia ignoring that standard.)

1) The only ones adversely affected by the Windshield Repair Industry are the individuals in the Glass Replacement Industry, and they are the ones who formed the committee. They purportedly had conducted safety tests regarding repair, but when asked for a cop of the test so as to verify or refute against Repair statistics, the same test could not be produced.

2) The Standard would prohibit any repairs in the "critical" area. This area, as defined by the committee includes a 16" area covering the driver's and passenger's visual field (50% of the windshield I would say). The wiper zone, also mentioned, is irrelevant to repairs which are done properly and performed with the correct adhesives. Also, Ultra BOND technicians give each customer a guarantee on their repair as we have for 6 years.

3) The Standard sets limitations on crack repair at 4". The reason for this was not clear. However, what our experience has revealed is that the length of the crack does not determine whether or not the repair can be performed adequately. Our investigation revealed that 80% of 18" cracks are repairable because they are clean or cleanable, and only 20% of 24" cracks are repairable, both due to the length of time the crack has existed in the windshield (dirt accumulation, and/or lamination deterioration) and which can be detected.

4) The Standard fails to recognize the importance of the resin (adhesive) properties used in repair. This is exactly what the Standard should be based on. It does not matter if a repair is 18" or 1" if a poor quality, poor bonding resin is used. If a correct procedure combined with the correct resins containing the appropriate resin properties is used, an acceptable repair can be performed, with a guarantee on the break not to spread and to pass State inspections.

5) Structural integrity is alleged by the Glass Industry as being sacrificed when a repair is performed. However, a small survey of local replacement companies indicated that replacement companies were not allowing the proper cure time on windshield replacements (a serious safety hazard). The adhesives used by Ultra BOND are 50-200% stronger (adhesive and tensile) than the adhesives currently used in replacement.

6) The standard suggests that cracks continue to expand. As indicated my survey, 98.6% of repairs performed by Ultra BOND technicians did not spread.

7) They also suggested that glass dislodgement could be caused ba a repair. The chance of a dislodgement of one layer of glass would be more likely due to a manufacturer's defect. A survey conducted of paramedics and windshield installers has confirmed this.

Opposing parties fought hard against the committee and the standard and they were trying to pass. Let me also share with you that the repair industry has had not one law suit filed against it in its 20 years plus of existence. If it ain't broke, don't fix it! It seemed as if the committee was going to have to reconsider their motion.

However, after hearing that the replacement industry suffered a 20% cut last year, the rumors have circulated that they will continue to press the standard and have allowed one Repair Distributor on the committee. We also have the understanding that they will try to sell it to the U.S. Department of Transportation and the insurance companies, who are just finally realizing the savings repair can offer them. We are angry and upset that this standard will be recognized when the only apparent reason for its existence is for the gain of the Replacement Industry's pocketbook. We fear its another example of the one with the most money wins.

In summary, we find the standard to be archaic in its structure and the committee prejudicial (the issue unnecessary). If you have any recommendations on how we might prevent the damage this standard will cause, to not only Ultra BOND but to the over 760 existing customers we have, as well as the thousands of other individuals who earn their living repairing windshields. We would greatly appreciate your input on this predicament.

P.S. Repair of windshields, along with the savings to the insurance industry, is a great savings to the environment. It prevents accumulation of windshields that are currently not recycled.

We have enclosed two videos for your perusal, one is submitted to educate the insurance companies about repair and one is a "live" video of repairs

being performed by our service and used in training. A letter directed to USAA Western Insurance disclosing some unethical traits of the replacement industry is also enclosed.