Interpretation ID: aiam1033
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC 20006;
Dear Mr. Humphreys: This is in reply to your letter of January 31, 1973, requesting severa interpretations of Motor Vehicle Safety Standard No. 205, 'Glazing Materials', as it applies to motor homes and campers.; We find the interpretations as to the use of item 3 glazing containe in your letter to be correct. Your interpretation of 'levels not requisite for driving visibility' as meaning that other windows are available and more suited for driving visibility is reasonable, and acceptable for purposes of Standard No. 205.; We also find your interpretations on the use of items 4, 5, 8, and glazing materials to be correct. We do not agree, however, with your suggestion of allowing items 5 and 9 glazing to be used in camper windows adjacent to the truck cab rear window without regard to driving visibility. We agree it is unlikely with respect to most vehicles that such windows will be requisite for driving visibility, and will accept a good-faith, reasonable judgment decision on the question by a camper manufacturer. Consequently we do not believe that the remaining 'degree of uncertainty' will result in compliance problems for camper manufacturers.; Your conclusions regarding the application of items 6 and 7 glazing ar correct. We do not agree, however, that it is necessary or desirable to use such materials in any forward-facing windows, including those adjacent to the rear window of the truck cab. We believe the possibility of impact into these windows precludes the safe use in them of these glazing items, and item 13 glazing as well.; Your conclusions regarding the application of item 12 and item 1 glazing are correct. We appreciate your pointing out the lack of continuity in subparagraph designations for items 6, 7, 8, and 9. This was unintentional on our part, and your conclusion that the added subparagraphs should be read as following immediately those existing, regardless of letter designation, is correct. Finally, you are correct in your conclusion that the amendments to Standard No. 205 should be seen as overriding the headings for the various glazing items in the ANS Z26 standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel