Interpretation ID: nht93-6.18

DATE: August 18, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Durin B. Rogers -- Saperstein (Saperston) & Day, P.C.

TITLE: None

ATTACHMT: Attached to letter dated 7/1/91 from Paul Jackson Rice to Richard E. Wright (Std. 205); Also attached to letter dated 11-29-84 from Frank Berndt to Wayne Ivie (Std. 205); Also attached to letter dated 7/8/93 from Durin B. Rogers to John Womack (OCC 8865)

TEXT:

This responds to your question about whether Standard No. 205, Glazing Materials, (49 CFR S571.205), applies to side windows in what you refer to as "fifth wheel campers/trailers." A picture accompanying your letter indicates that the camper has a tandem rear axle and is towed by a powered vehicle. As explained below, glazing materials used in new or used trailers are not covered by Standard No. 205.

Each Federal motor vehicle safety standard has an application section which specifies the vehicles or equipment to which the standard applies. Standard No. 205 sets performance requirements for glazing used in a wide range of vehicles. It does not, however, apply to trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle" (49 CFR S571.3).

You also asked about Federal or industrial regulations that require use of Standard No. 205 glazing for window replacements and/or repairs. Standard No. 205 applies to aftermarket glazing materials for certain vehicle types. However, the standard does not apply to replacement glazing for use in trailers. There are no Federal regulations that would require Standard No. 205 glazing for window replacements or repairs, nor are we aware of any industry regulations about the replacement of glazing. You may wish to check with the State of New York which has the authority to regulate the operation and modification of vehicles by their owners. New York may have used this authority to issue regulations about replacing or repairing damaged glazing.

I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.