Interpretation ID: nht75-4.20

DATE: 03/28/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The Glass Doctor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter dated January 29, 1975, asking whether a product which you use to repair damaged windshields is prohibited by Federal law or regulation. Your letter was forwarded to our office by the NHTSA Regional Administrator in Fort Worth. You describe the repair process which you use as one in which the air in a damage spot or crack in the windshield is displaced by the product in a liquid form. As this product hardens it bonds itself to the glass, making the damaged area stronger than the other areas of the glass.

There are no Federal laws or regulations which prohibit the use of such a material or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new (but damaged) windshield (such as in shipment) could cause the windshield to fail to meet the performance requirements of Motor Vehicle Safety Standard No. 205 (49 CFR @ 571.205) and we would therefore discourage its use in new windshields.

We are pleased to be of assistance.

Yours truly,

ATTACH.

The Glass Doctor

JANUARY 29, 1975

Dept. of Transportation-NHTS Legal Dept., Fort Worth, Texas 76102

Gentlemen:

The Glass Doctor has a patented compound and patented process for repairing damaged glass on vehicular windshields. The compound is a lucite or plexiglass base product which must be kept dark and refrigerated prior to use. Once exposed to sunlight (ultra-violet) and heat, the hardening process commences. This process is irreversible, similar to cement.

Repairs to windshield damages are accomplished through a process by which the air in a damage spot or crack on the windshield is displaced by the product while same is still a low viscosity fluid. As the compound hardens, it bonds itself to the glass, making the damaged area actually stronger than the other areas of the glass. A good analogy is that of welding two pieces of metal together. The same principle applies to our glass repair compound and process. We are able to confine existing damage, restore the strength of the glass, and improve the cosmetics of the damage anywhere from 75% to 99%.

In the course of offering our repair service to many of the Motor Freight Trucking firms in the Dallas area, the question has been raised as to whether use of our repair process would be in conflict with existing D.O.T. regulations.

Would appreciate greatly any correspondance from your department which would ascertain that use of our process would in no way conflict with existing D.O.T. regulations.

Sincerely,

E. J. Banks