Interpretation ID: nht70-2.9

DATE: 05/13/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 2, 1970, petitioning for amendments to Federal motor vehicle safety standard No. 205-Glazing Materials. I apologize for the delay in this response to your petition.

The first amendment you propose would require each manufacturer to mark each piece of glazing material with his name, the model number and "AS" classification. A manufacturer electing the certification alternative now in S3.4 must provide the same information you request, except that a code number is substituted for the manufacturer's name. In this connection, the Director of the National Highway Safety Bureau is considering the issuance of a notice of proposed rule making which would require all manufacturers of glazing materials to adopt the certification method in S3.4. Consequently, while we are not granting your petition on identification requirements, we are actively considering your suggestions for future rule making.

The second amendment you propose would add to the standard a definition of "area requisite for driving visibility." Subsequent to the writing of your letter, the Director issued an advance notice of proposed rule making concerning a new standard, Direct Fields of View. In this notice, a copy of which is enclosed for your convenience, the Director announced that he was

considering the establishment of performance requirements for (1) direct fields of view outside the vehicle in all directions to provide adequate visibility for the driver from specified eye reference loci; (2) light transmission characteristics (including maximum

levels of tinting) of vehicle glazing materials; and (3) shade band boundaries of vehicle glazing materials. (Emphasis added)

Requirements developed with regard to items (3) and (3) would supercede provisions regarding shade band boundaries and tinting in standard No. 205. If this new standard is issued, it will deal with the problem which you mention.

We would welcome any additional comments you may have on these matters.

ENCLOSURES