Interpretation ID: nht95-1.80

TYPE: INTERPRETATION-NHTSA

DATE: February 27, 1995

FROM: Bill Lieb -- Regional Sales Mgr., Restech

TO: Philip Recht, Office Of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHIL RECHT TO BILL LIEB (A43; STD. 108)

TEXT: Dear Mr. Recht,

I am a sales manager for Fel-Pro Chemical Products in Denver, CO. My company formulates epoxy adhesives for many different applications including the automotive industry.

We have formulated an adhesive that has been tested by a manufacturer of sealed beam automotive head lamps. The manufacturer was told by the current supplier of the adhesive that D.O.T. 'approval' is required prior to changing the adhesive used on the h ead lamps.

We have been referred to 'Motor Vehicle Safety Standard No. '108' for the appropriate test requirements on the adhesive. However this standard does not say anything about adhesives.

I then contacted Mr. Laubis in the Office of Vehicle Safety & Compliance, Enforcement Section. Mr. Laubis told me that D.O.T. does not test, approve, or specify any adhesives, but just verifies that the completed unit meets the prescribed standards, and passes the appropriate tests. Is this correct?

If this information is correct, would it be possible for you to provide me with something in writing to confirm this information? As of today, it is my word against the word of the other adhesive vendor, who say's that D.O.T. 'approval' is required. I need something to give to the manufacturer to confirm the information that I have, and to let them know that they are not locked into an old material if they want to change.

Thank you very much for your help.