Interpretation ID: nht73-1.46

DATE: 04/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Windows, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 27, 1973, requesting information on requirements for marking glazing materials for use in motor vehicles, and whether you must finish cleaning instructions for glazing you manufacture.

Your questions regarding marking requirements are similar to those raised by Mrs. Lewis Cook of your company, in a letter of February 20, 1973. We responded to that letter on April 4, 1973 (a copy is enclosed), and you should have received our response by this time. In that letter we stated that your responsibilities as a manufacturer who cuts glazing materials are to mark that material in conformity with section 6 of ANS Z26.1-1966. We should amplify our response in that letter by stating that if the glazing material as you receive it already contains the required markings, you may use those markings in meeting the requirements.

You indicate your question concerning requirements for cleaning instructions arises from a customer to whom you furnished Rohm and Haas Plexiglas. Paragraph S5.2.1.3 of Standard No. 205 provides that glazing materials designated AS-12 or AS-13 must be labeled (using a label that is removable by hand) with cleaning instructions. If the Rohm and Haas Plexiglas is of either of these glazing designations, it must be so labeled. If it is not, there are no requirements that cleaning instructions be furnished.

Yours truly,

Enclosure

March 27, 1973

Office of Chief Counsel National Highway Traffic Safety Administration

Dear Sirs:

We at Young Windows, Inc. are in the business of manufacturing custom windows for the transportation industry. Recently a few questions were raised that have sent me seeking the correct answers.

My questions concern certification of certain glazing materials we presently use in our windows. Before I go any farther, let me explain that we do not manufacture windshields for the automotive industry but rather windows for campers earthmoving equipment, marine windows, and some rear windows for the truck industry. Therefore, what type of certification is needed concerning Federal Standard Number 205 of the Safety Code. I have heard a label is needed on the window, a label could be placed on the outside of the box, or a tag,(Illegible Word) that the glass in the windows meets Standard 205. Since our glass comes in stenciled with all necessary markings, would this be sufficient? If not, what would we be required to do to meet and conform to Standard #205?

Another question has been brought to our attention by one of our customers. We recently shipped 360 windows to a manufacturer of food serving and ice cream vending trucks. We supplied the sliding serving window. Per customer request, we supplied the windows using Rohm and Haas Plexiglas. The material was branded with all the necessary marking. Our customer has now come back and ask for cleaning instructions on the Plexiglas. Are we required by any Federal Standard to supply cleaning instructions with these windows?

I would appreciate your kind and prompt reply, as we want to conform to all standards without delay.

Regards,

Yours truly,

YOUNG WINDOWS, INC.

Charles E. Smith,

Purchasing Manager