Interpretation ID: nht73-1.47

DATE: 03/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 31, 1973, requesting several interpretations of Motor Vehicle Safety Standard No. 205, "Glazing Materials", as it applies to motor homes and campers.

We find the interpretations as to the use of item 3 glazing contained in your letter to be correct. Your interpretation of "levels not requisite for driving visibility" as meaning that other windows are available and more suited for driving visibility is reasonable, and acceptable for purposes of Standard No. 205.

We also find your interpretations on the use of items 4, 5, 8, and 9 glazing materials to be correct. We do not agree, however, with your suggestion of allowing items 5 and 9 glazing to be used in camper windows adjacent to the truck cab rear window without regard to driving visibility. We agree it is unlikely with respect to most vehicles that such windows will be requisite for driving visibility, and will accept a good-faith, reasonable judgment decision on the question by a camper manufacturer. Consequently we do not believe that the remaining "degree of uncertainty" will result in compliance problems for camper manufacturers.

Your conclusions regarding the application of items 6 and 7 glazing are correct. We do not agree, however, that it is necessary or desirable to use such materials in any forward-facing windows, including those adjacent to the rear window of the truck cab. We believe the possibility of impact into these windows precludes the safe use in them of these glazing items, and item 13 glazing as well.

Your conclusions regarding the application of item 12 and item 13 glazing are correct. We appreciate your pointing out the lack of continuity in subparagraph designations for items 6, 7, 8, and 9. This was unintentional on our part, and your conclusion that the added subparagraphs should be read as following immediately those existing, regardless of letter designation, is correct. Finally, you are correct in your conclusion that the amendments to Standard No. 205 should be seen as overriding the headings for the various glazing items in the ANS Z26 standard.

Yours truly,

January 31, 1973

Lawrence R. Schneider--

Chief Counsel,

National Highway Traffic Safety Administration

U.S. Department of Transportation

Dear Larry:

This letter seeks your confirmation of our interpretation of certain aspects of Standard No. 205, as amended on June 21, 1972 and November 11, 1972, or your advice as to proper interpretation if we are incorrect.

The language of the cited amendments leaves as a qualification on the use of various item of glazing materials the phrase "at levels not requisite for driving visibility" or a similar qualification slightly varied depending upon the item of glazing involved. Insofar as we are aware, there has not been an interpretation of this qualification and we have had member inquiries on its application to certain windows of our units. Our subsequent comments will refer to the questionable items of glazing as they are listed in ANSI Z.26.

Item 3. Paragraph S5.1.1.5 of the November 11 amendment prescribes that motor homes, as multipurpose passenger vehicles, will be treated as trucks where not otherwise specifically provided for in the standard. Thus we conclude that:

(1) Item 3 cannot be usedfor windows to the immediate right or left of the driver of a motor home unless such windows are at levels not requisite for driving visibility which we would take to mean windows not required for visibility to the right and left of the driver because other windows are available and more suited for that purpose.

(2) The rear window of a motor home, where so equipped, may utilize Item 3 where it is not in fact used for or designed for driving visibility because of the impracticability for doing so and where outside side view mirrors are provided in accordance with Standard No. 111. In this connection, we have reference also to the opinion by Mr. Francis Armstrong of April 16, 1971, advising that rearview mirrors are not required in motor homes of configurations which obstruct the view to the rear to such an extent it could not meet the requirements of the Standard No. 111; and the interpretation incorporated with Standard No. 111.

Items 4, 5, 8, 9:

(a) These items cannot be usedin windshields or windows of motor homes to the immediate rigth or left of the driver.

(b) These items can be usedIn all other windows and doors of motor homes including over-the-cab forward-facing windows in those configurations which have space over the vehicle cab and a forward-facing window therein; and including those relatively few configurations where there may be a window in the motor home and/or a window in the cab just behind the driving compartment. Some few configurations may use a truck chassis and cab without a passageway directly from the driving compartment into the living quarters.

(c) These items can be used in all windows and doors of slide-in-campers and pickup covers, including any over-the-cab forward-facing window and any window in the slide-in-camper or pickup cover immediately behind the driving compartment.

In connection with both (b) and (c) above, we note that Items 5 and 9 carry the qualification of use only "at levels not requisite for driving visibility". Items 4 and 8 are not so limited. Over-the-cab forward-facing windows in motor homes, slide-in-campers and pickup covers (these units are unlikely to have such windows) clearly are not at levels requisite for driving visibility. Windows in the slide-in-camper or pickup cover just behind the driving compartment of the pickup truck on which such units are temporarily mounted are not generally used for driving visibility since pickup trucks customarily carry outside side-view mirrors to provide requisite rearview capability in the light of their property carrying function when used separately from a slide-in-camper or pickup cover. Although pickup trucks are not required by a current standard to have side-view mirrors, it seems appropriate and consistent with the actual practice to recognize that, in fact, they do and thus the windows described are not "requisite to driving visibility", rather than leave a degree of uncertainty on the part of the manufacturer of slide-in-campers and pickup covers as to whether Items 5 and 9 can be used in such windows.

The conclusion with respect to motor homes is predicated on the same reasoning as applied under Item 3 above. These conclusions also seem consistent with the opinion rendered to Mr. Robert T. Sanders on July 5, 1972 by Mr. Dyson.

Items 6 and 7:

These items cannot be usedin windshields, forward-facing windows (including over-the-cab forward-facing windows), and windows to the immediate right or left of the driver in motor homes; similarly, they cannot be usedin forward-facing windows, including over-the-cab forward-facing windows of slide-in-campers and pickup covers.

We note that Item 6 is not limited by the qualification that the locations not be requisite for driving visibility but Item 7 is so qualified. For the same practical reasons as set forth in regard to Items 4, 5, 8 and 9, above, we would conclude that the small windows in slide-in-campers, pickup covers, and a few configurations of motor homes just behind the driving compartment of the pickup truck can use Items 6 and 7, except for the fact they are "forward-facing" in the directional sense; neither item requires compliance with a test related to penetration resistance; and the cited opinion of July 5, 1972 by Mr. Dyson. RVI still feels that safety does not require penetration resistance characteristics in these behind-the-cab windows and requests your reconsideration as to whether such windows must be considered as "forward-facing" windows in connection with the possible use of Items 6 and 7 in such behind-the-cab windows.

Items 12 and 13, Rigid and Flexible Plastics:

Both of these items, as authorized by the amendment of June 21, 1972 contain the limitation of use only at "specific locations at levels not requisite to driving visibility". Based on the reasoning and opinions above cited, we conclude that:

(1) Item 12 can be usedin over-the-cab forward-facing windows of motor homes, slide-in-campers, and pickup covers, and in all such units in the windows behind the cabs of motor homes which have such configurations and behind the cabs of pickup trucks on which slide-in-campers and pickup covers are mounted.

(2) Item 13 cannot be usedin over-the cab forward-facing windows of such units including windows behind cabs. However, for the same reasons as expressed in connection with Items 6 and 7, we request your reconsideration as to whether such behind the cab windows must be considered "forward-facing" windows.

Other matters of interpretation:

(1) We note that, in the process of the amendment of November 1, 1972, subparagraphs "j" and "k" were added to Items 6, 7, 8 and 9 of ANSI - Z.26 although the subparagraphs in those items do not go beyond "(d)", "(c)", "(e)" and "(c)", respectively. We interpret the amendments as adding paragraphs falling immediately after the numbering of the appropriate subparagraph.

(2) We note that the headings in the same items are generally descriptive of other units than motor homes, slide-in-campers, and pickup covers. We interpret the amendments as overriding the headings and as controlling in the case of these recreational units.

Very truly yours,

David J. Humphreys --

RVI Washington Counsel