Interpretation ID: 77-4.31

TYPE: INTERPRETATION-NHTSA

DATE: 11/08/77

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: Grand Teton Trading Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 12, 1977, requesting information concerning the certification requirements for acrylic glazing to be used in motor vehicles. Specifically, you are interested in the separate certification responsibilities of the company that manufactures the acrylic sheets, the company that cuts and shapes the acrylic, and the company that constructs aluminum frames around the acrylic and sells windows to the customized van market.

Paragraphs S6.1 and S6.3 of Safety Standard No. 205, Glazing Materials, specify that prime glazing material manufacturers shall certify each piece of glazing that is for use in motor vehicles in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, et seq.) and with section 6 of the ANS Z26 standard. These requirements would be applicable to the company from which you buy acrylic sheets, since that company would qualify as a prime glazing material manufacturer.

As a manufacturer or distributor who cuts a section of glazing for use in a motor vehicle, your company would be required to certify its product in the same fashion as your supplier (paragraphs S6.4 and S6.5 of Standard No. 205). Please note, however, that under section 6 of ANS Z26 your company is required to mark any section of glazing that it cuts with the same words, designations, characters, and numerals as the piece of glazing from which it was cut. This means that you would stamp your product with markings identical to the certification markings on the acrylic sheets you purchased.

The company that constructs aluminum around the glazing and sells windows to the customized van market would be required to certify its product in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act. Section 114 provides that an item of motor vehicle equipment (including glazing) may be certified by means of a label or tag on the item of equipment or on the outside of a container in which the equipment is delivered. The label or tag must certify that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, Standard No. 205 in this case.

Please contact this office if you have any further questions.

SINCERELY,

GRAND TETON TRADING CO.

September 12, 1977

Guy Hunter Office of Chief Counsel NHTSA

I have been advised by Mr. Bradley Marks of your Colorado office to write you concerning clarifications of the Motor Vehicle Standard No. 205.

We are a company who intends to purchase acrylic sheets from a manufacturer that states his product has been certified to meet the requirements of ANSI-Z26. We intend to cut sections of the acrylic sheets to various shapes that will be used as window inserts. Our customer will construct aluminum frames around the acrylic insert and market the window to the customized van market.

Based upon the situation stated above, I have the following questions:

1. What should I expect from the manufacturer of the acrylic sheets in the area of ANSI-Z26 certification?

2. What is our company required to do to comply with ANSI-Z26?

3. What is our customer required to do to comply with ANSI-Z26?

This is a new market area for our company and we would appreciate any information and clarification you can provide.

Robert P. Ducey