Interpretation ID: nht94-4.44

TYPE: INTERPRETATION-NHTSA

DATE: October 4, 1994

FROM: Brigitte Neifer -- Safety Standards/Certifications, Sekurit Saint-Gobain Deutschland

TO: Dan Colhen -- Safety Compliance, NHTSA

TITLE: 1) Docket 89-15; 2) AAMVA activities

ATTACHMT: ATTACHED TO 2/17/95 LETTER FROM PHILIP R. RECHT TO BRIGITTE NEIFER (A43; STD. 205)

TEXT: 1) [Illegible Words] Please inform me if NHTSA is planning further activity on this docket. I have not heard of further activities - published in the FR - since July 1992.

2) AAMVA: I have been informed that AAMVA have given up involvement in the Safety Equipment Compliance Program, which has obviously lost importance, due to the increasing preemption of state regulations by the federal government. I therefore intend to limit our a ctivities to having our products tested by ANSI standard in independent laboratories such as ETL in Cortland or other European labs. I understand that the 5-year rhythm of renewal was an AAMVA procedure and not an official requirement. Am I right?

I nevertheless intend to have our products regularly tested by independent laboratories and think DOT inspectors in USA will accept (cars equipped with) our glazings when accompanied only with a test report. Is this correct?

I would appreciate any comment, information, advice and warning of NHTSA concerning my evaluation of the situation. I know rather little about US legal requirements of showing compliance of production with ANSI Z26.1 apart from test reports.