Interpretation ID: nht72-3.20

DATE: 12/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailer Coach Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of August 17, 1972. We indicated in a letter to you of September 8, 1972, that we would respond to your letter when action on petitions for reconsideration of the June 21, 1972, amendment to Standard No. 205 had been completed. Notice of our action has now been published 137 F.R. 24035, November 11, 1972) and a copy is enclosed.

Based upon the November 11, 1972, notice, your conclusions regarding the requirements for certification and marketing by prime glazing material manufacturers (paragraph 3.2 of your letter) are for the most part correct. These manufacturers must mark glazing materials in accordance with Section 6 of ANS (Illegible Word). They must also certify. The certification must be made by the addition of the symbol DOT and assigned code number only when the glazing is designed as a component of any specific motor vehicle or camper. In other cases certification may be accomplished by any method meeting the requirements of section 114 of the National Traffic and Motor Vehicle Safety Act (13 U.S.C. 1403). It may not be accomplished, however, by affixing the DOT and code number.

Your conclusions regarding certification and marking requirements for persons who cut glazing material from larger sheets (paragraph 3.1 of your letter) are not entirely correct. It is true that such persons must also certify, and that the method for certification may be any that satisfies the requirements of section 114 of the Act. Affixing a label to the material is one such method. You are incorrect, however, in your conclusion that the material need not contain the markings of the prime manufacturer. Section 6 of ANS %26 requires glazing cut from larger pieces to contain the markings of the manufacturer of the larger piece. As clarified in the notice of November 11, 1972, this requirement is still applicable.