Interpretation ID: GF003409-2

Mr. Lance Tunick
Vehicle Services Consulting, Inc.
PO Box 23078
Santa Fe, NM 87502-3078

Dear Mr. Tunick:

This responds to your e-mail of March 22, 2004, in which you ask several questions with respect to a hardtop convertible vehicle equipped with a retractable glass roof. The vehicle in question will have a tinted glass roof, which retracts rearward to a stowed position inside the vehicles rear deck (trunk). A thin carbon fiber frame will surround the glass roof panel. A latch mechanism secures the roof to the windshield header when the roof is not stowed. You ask whether the glass roof, as well as carbon fiber frame and latch mechanism are exempt from the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant protection in interior impact. You also ask what roof glazing materials would comply with FMVSS No. 205, Glazing materials.

In establishing FMVSS No. 201, the agency excluded convertible roof frames and linkage mechanisms from the requirements of the standard because a countermeasure such as padding would interfere with their movement (see 60 FR 43031, at 43047). S6.3(a) of FMVSS No. 201 provides that a vehicle need not meet the requirements of S6.1 through S6.2 for any target located on a convertible roof frame or a convertible roof linkage mechanism. Accordingly, the carbon fiber roof frame and the latch mechanism in your vehicle are exempt from S6.1 and S6.2 of FMVSS No. 201.

With respect to the glass portion of the convertible roof in your vehicle, the agency has previously stated that FMVSS No. 201 was not intended to prevent injuries resulting from impacts with glazing. Accordingly, the glass portion of the convertible roof is not subject to the requirements of FMVSS No. 201.

Finally, FMVSS No. 205 contains no light transmittance requirements applicable to a glass roof described in your letter because roof glazing is in an area not requisite for driver visibility. The type of glazing material that can be used in the glass portion of the convertible roof is any glazing material subject to FMVSS No. 205, including glazing materials incorporated by reference from ANSI/SAE Z26.11996.

I hope this information is helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:201
d.7/19/04