Interpretation ID: nht94-2.73

TYPE: INTERPRETATION-NHTSA

DATE: May 6, 1994

FROM: David L. Ori -- Manager Vehicle Control Division, Bureau of Motor Vehicles, Pennsylvania Dept. of Transportation

TO: Jim Gilkey -- NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 09/07/94 from John Womack to David Ori (A42; STD. 205; Part 567

TEXT: I would like to thank you for the assistance you gave to one of my staff members, Kris Singer, when she recently telephoned you regarding Federal glazing standards relating to limousines. Since the Pennsylvania Department of Transportation is addressing this issue at the present time, I would appreciate your assistance in confirming the information which Mrs. Singer received.

You explained that limousines which seat less than ten persons are categorized as passenger cars for the purpose of Federal Motor Vehicle Safety Standard 205 (FMVSS 205). As such, these vehicles may not be equipped with any sun screening or window tintin g product which does not meet FMVSS 205. This prohibition also applies to vehicle modifications completed during the second stage or alteration phase of the manufacturing process. Further, the company which alters the original vehicle is required to ce rtify that the finished product is still in compliance with FMVSS 205.

Limousines which seat ten or more persons are categorized as buses and, therefore, would not be restricted regarding the use of sun screening products on windows located behind the driver's area of the vehicle. These vehicles would also require certific ation from the second stage manufacturer of continued compliance with FMVSS 205.

I would appreciate receiving your confirmation of the above information, at your earliest convenience, at the Bureau of Motor Vehicles, Vehicle Control Division, Room 104, T & S Building, Harrisburg, PA 17120. If there is any additional information whic h you feel may be pertinent to Pennsylvania's efforts to address this issue, please include it with your response, or contact me at (717) 787-3184.