Interpretation ID: nht78-1.5

DATE: 03/22/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: J. Kawano

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. J. Kawano 1099 Wall Street, West Lyndhurst, New Jersey 07071

Dear Mr. Kawano:

This responds to your January 23, 1978, letter asking whether Safety Standard No. 205, Glazing Materials, would be applicable to tempered glass mounted on the outside panel of a vehicle "B-pillar" for ornamental purposes.

The answer to your question is no. Since there would be no danger that vehicle occupants would contact the ornamental glass, it would not have to comply with the performance and location requirements of Standard No. 205. This interpretation assumes, of course, that the glass is used only on the outside panel of a solid "B-pillar". Standard No. 205 would be applicable, for example, if the glass were used in a cut-out section of a "B-pillar", such that there was an interface of the glass with the vehicle occupant compartment.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

January 23, 1978

Mr. Joseph Levin, Chief Council National Highway Traffic Safety Adm. 400 Seventh Street, S.W. Washington, D.C. 20590

Interpretation Request of FMVSS 205

Dear Mr. Levin:

This is to confirm your interpretation as to whether tempered glass mounted on the outside panel of a B-pillar for ornamental purposes, as shown in Fig.1, falls into the application of FMVSS 205, "Glazing Materials."

The glass will be adhered, at every point, to the garnish which is bolted to the B-pillar outer panel. This can be observed in Fig.2 which shows the A-A section of Fig.1. In cases where the glass is broken into pieces, even though the glass has AS 3 performance equivalency, the fragment will not come out from the garnish because of the adhesion.

As we understand, FMVSS 205, "Glazing Materials," would not apply to such glass that is mounted simply for the purpose of ornamentation, as we mentioned above. However, your confirmation of our understanding will be very much appreciated.

Since this is an urgent matter, we would appreciate your expeditious interpretation.

Sincerely yours,

TOYOTA MOTOR SALES, U.S.A., INC.

J. Kawano Director/General Manager Factory Representative Office

JK:gc