Interpretation ID: 6973
Safety Systems Company
23 Seminole Avenue
Baltimore, MD 21228-5638
Dear Dr. Clark:
This responds to your request for an interpretation of Standard No. 205, Glazing Materials (49 CFR 571.205). More specifically, your letter indicated your belief that Standard No. 205 permits a prime glazing material manufacturer to designate an item of glass-plastic glazing that it manufactures as "Item 14" glazing if that glass- plastic glazing item passes all the tests specified for Item 14 glazing. It is your view that it is irrelevant whether the individual glass layers in the glass-plastic glazing are tempered or annealed glass. Your understanding is correct.
Standard No. 205 specifies the performance requirements for Item 14 glazing, through a series of 14 tests designated for that item of glass-plastic glazing material. No test applicable to Item 14 glazing specifies that any individual layer, either glass or plastic, of this laminated glazing is to be tested separately. Instead, the 14 tests applicable to Item 14 glazing set forth performance levels that must be achieved by the glazing as a laminate.
One of the 14 tests designated for Item 14 is Penetration Resistance, Test No. 26. You are correct in noting that, effective September 23, 1991, Test No. 26 specifies the glass-plastic specimen is to be clamped into a test fixture before the specimen is tested. If an item of glass-plastic glazing passes each of the 14 tests applicable to Item 14 glazing, including Test No. 26, with clamping, and complies with Standard No. 205's labeling and certification requirements, the prime glazing material manufacturer of the material may designate that item of glass-plastic glazing as Item 14 glazing.
You were also correct in your understanding that Standard No. 205 permits Item 14 glazing to be used for passenger car glazing in any position except the windshield of convertibles.
I hope this information is helpful. Please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:205 d:3/5/92