Interpretation ID: nht76-4.33

DATE: 05/07/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Free Enterprise Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 12, 1976, request for a listing of Federal motor vehicle safety standards that apply to the manufacturer of a fiberglass hardtop for installation on a Jeep. I am assuming that this top is an aftermarket item and is not incorporated by the Jeep Corporation as the vehicle roof of its product.

The only Federal motor vehicle safety standard applicable to this item of aftermarket motor vehicle equipment is Standard No. 205, Glazing Materials, 49 CFR 571.205. Standard No. 205 specifies requirements for glazing materials used in motor vehicles and motor vehicle equipment, including a vehicle top such as you describe. Any glazing material used in the construction of your Jeep top must be certified as being in compliance with Standard No. 205, even though the top itself does not have to be certified. Generally, the prime glazing manufacturer or the glazing fabricator certifies the glazing, so your main concern as manufacturer of the Jeep top is to make certain that you use glazing that has been certified as being in compliance with the standard. If you obtain sheets of glazing from a prime glazing manufacturer and fabricate or mold the glazing yourself, you must mark and certify the glazing as specified in paragraphs S6.4 and S6.5 of Standard No. 205. A copy of the standard is enclosed for your information.

Enclosure

ATTACH.

March 12, 1976

Chief Council -- National Highway Traffic Safety Administration

Re: Fiberglass Jeep Top - Safety Requirements

Dear Chief Council:

Our company is presently preparing to mass produce and market a fiberglass hardtop for Jeep Model CJ-5. The top will include five windows, three of which open, two side doors, and one rear lift-up door.

Before we market any tops or commit ourselves irretrievably to a particular form, we need to find out what safety regulations might apply to our product. Therefore, please send us a listing of what requirements for general construction and materials (reinforcement, glass, crash tests, etc.) would apply. In particular, what do the regulations have to say about "suicide" doors (or, doors hinged at the back).

Thank you for your assistance.

Sincerely,

Paula J. Redford (Mrs.) -- Manager, Free Enterprise Company