Interpretation ID: nht71-3.40

DATE: 07/11/71

FROM: CLUE D. FERGUSON -- NHTSA; SIGNATURE BY J. ZEMAITIS

TO: Triplex Safety Glass Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of June 18 and 21, 1971, concerning the application of the proposed requirements for glazing materials (Docket 71-1, Notice 1) as they would apply to heated rear windows and mirrors.

In your letter of June 18 you state that the heating lines used in the rear window continue almost to the bottom of the glass at the ends. You propose putting an abbreviated mark at the bottom left hand corner, with the full trade mark appearing at the bottom center, and ask whether this would(Illegible Word) with the proposed requirements. The answer to this question is no. Paragraph S5.5 of the proposed amendment would require the complete mark to be placed in either the lower left or right hand corner of the rear window.

Your letter of June 21 asks whether it is likely that there will be further amendment to Standard No. 205. You mention that you were told that the proposed amendment should have referred to interior vanity mirrors and not the normal rear view mirror. Finally, you state that if the proposed requirements apply to the normal rear view mirror, you will need to do additional development work.

The proposed amendment to Standard No. 205 is still under consideration, and no final determination has been made as to whether the proposal, or any part of it, will be issued as a final rule. With reference to your comments concerning the normal rear view mirror, S4.3 of the proposal clearly refers to glazing for use in all interior mirrors, including both the normal rear view mirror, and any other interior mirror, such as a vanity mirror. With reference to your comments concerning the need for additional development work, adequate lead times will be provided for in any final rule that is issued.

Copies of your letters will be placed in Docket No. 71-1.