Interpretation ID: aiam4144
Quality Manager
Sierracin/TransTech
12780 San Fernando Road
Sylmar
CA 91342;
Dear Mr. Burns: Thank you for your letter of March 7, 1986, to Edward Jettner of thi agency. Your letter was referred to this office for reply. You asked about the effect of the certification requirements of Standard No. 205, *Glazing Materials*, on a product you are planning to manufacture. I hope the following discussion answers your questions.; You described your product as an aftermarket personal securit specialty glazing for automotive use. The glazing would be manufactured by adding a special plastic to the interior surface of a piece of new glazing. You explained that you are having testing conducted on your product and believe that it will pass all of the requirements set for glass-plastic glazing (item AS-14) in Standard No. 205. Your specific question concerns how the glazing is to be marked in accordance with S6 of the standard.; You explained that a new item of glazing is sent to you by an origina equipment glazing manufacturer, who has certified the glazing as complying with the standard and placed the necessary markings, required by S6 of the standard, on the glazing. You asked whether you should obliterate the OEM markings through sandblasting or other means and then apply your own identification or whether you should retain the OEM marking and add additional information to indicate that the glazing has been modified.; S6.1 of Standard No. 205 requires prime glazing manufacturers to mar glazing materials in accordance with section 6 of ANS Z-26. S6.1 further defines a prime glazing manufacturer as one 'who fabricates, laminates, or tempers the glazing material.' In general, an item of glazing has only one prime glazing manufacturer, since usually one manufacturer performs the fabrication, lamination, or tempering of the glazing material. However, in the case of your product, we would consider both the original manufacturer of the glazing and your company, which laminates a plastic material to the glazing, to be prime glazing manufacturers. Both companies are performing a fundamental manufacturing operation, such as fabricating, laminating, or tempering, necessary to produce a completed item of glazing material, as compared to a situation where a company is performing a minor finishing operation, such as polishing, to an item of glazing that is fabricated, laminated, or tempered by another company.; As you pointed out in your letter, having two identifying marks on on item of glazing could lead to potential confusion as to which mark is correct. One of the purposes of the certification requirement is to assist in identifying the responsible manufacturer for the purposes of defect and noncompliance recall campaigns. Thus, in the case of your product, the agency believes that it is important that both prime glazing manufacturers be identified on the glazing since, for example, there could be a noncompliance in the original glazing sent to you or there could be a noncompliance in the glazing as modified by your company. To avoid potential confusion about what item number applies to your finished product, we agree that adding wording to your marking indicating that the original glazing has been modified from one AS item to another will help avoid confusion.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel