Interpretation ID: nht68-1.26

DATE: 07/29/68

FROM: DAVID SCHMELTZER FOR ROBERT M. O'MAHONEY -- NHTSA

TO: Anadite Products Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 23, 1958, in which you ask that:

1) We "confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 plastic film [and] . . . etched as required in Z25."

2) We confirm that anything less than edges(Illegible Word) specified in J573 [Society of automotive Engineering Recommended Practice J573 'automotive glazing', June 1950] will(Illegible Word) a window with unbanded edges a non-complying article.

3) We forward "the proper instructions for manufacturers who are being undersold due to non-complying competitors."

With regard to your first request, we cannot confirm that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 because windshields of multipurpose passenger vehicles must comply with the S-1 requirements. However, your request that slide-in campers be allowed to use S-1 liminated with an .030 plastic film in under consideration, and further reply will be made. You also ask for confirmation that the glazing be etched as required by Z25. This matter is also being considered as part of a rulemaking which would amend the glazing standard to provide for this type of etching.

With regard to your second request, Standard No. 205 presently requires that, except in school buses, expanded edges of glazing materials shall have an edge radius of between one half the nominal thickness of the material and inch. Exposed edges not meating these limits are not in compliance with the standard.

Finally, with the regard to your third request, if you have any additional information available concerning "non-complying competitors" please submit it to the National Highway Safety Bureau, Office of Motor Vehicle Safety Performance Service, 400 5th Street, S.W., Washington, D.C. 20591, and whatever action is considered appropriate will be taken.

Once again we wish to thank you for your active interest in the motor vehicle safety program.

Sincerely,

May 23, 1968

David Schmeltzer U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau Dear Dave:

This letter will serve as a formal request for information which we discussed in our telephone conversation of May 22.

Please confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with AS-2 laminated with .030 plastic film. Also, confirm that each glass pane must be etched as required in Z26.

One question we did not discuss has to do with windows with exposed edges. At the present time, Standard 205 requires that in all except school buses, windows with exposed edges must be treated in accordance with Society of Automotive Engineering Recommended Practice J673, "Automotive Glazing", June 1960. This includes the window we refer to as a 4" Jalousie. It would be convenient if you could justify written instructions that the radii specified in J673 for edge treatment will be necessary for compliance with Standard 205. The reason for this is that we "webber" (grind to no specific radius but remove enough edge material so that you would not cut your finger if you rubbed it along the edge of each unbanded pane) 4" Jalousie panes and have for many years. The information available from SAE is a little confusing, for it looks like a webbered edge; however, it specifies a radius from 3/16" to 1/4". As you know by now, it is difficult to take some of this Automotive Engineering data and use it without expanding its meaning when concerned with pickup canopies and campers. We are not asking for you to give us any relief or to approve the webbered edge as satisfactory. We concur in your decision that an unbanded edge should have a close tolerance and responsible radius. We only want to ascertain that anything less than edges as specified in J673 will make a window with unbanded edges a non-complying article.

One last point -- please expedite if possible the proper instructions for manufacturers who are being undersold due to non-complying competitors. I have requested this previously.

Sincerely yours,

ANADITE, INC.

PRODUCTS DIVISION --

John E. Orr

Director of Marketing