Interpretation ID: nht78-3.29

DATE: 04/14/78

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

TO: Grove Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. R. G. Wilkins Product Safety and Reliability Grove Manufacturing Co. Shady Grove, Pennsylvania 17256

Dear Mr. Wilkins:

This responds to your recent letter asking whether plastic glazing materials may be used on the superstructure operator cabs of mobile construction cranes. Apparently, the upper superstructure cab is used only for craning operations and is distinct from the cab used to drive the crane over public highways.

Under Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR Part 571.205), plastic glazing may be used only in locations to the rear of the driver in trucks or truck tractor cabs and only at levels not requisite for driving visibility. Therefore plastic glazing could not be used in the windshield or windows to the right or left of the driver in the main driving cab of the mobile crane. It is our interpretation, however, that the superstructure operator cab is, effectively, to the rear of the driver when the vehicle is being used on the highway and could be equipped with plastic glazing materials meeting the requirements of Standard No. 205. This interpretation assumes that the operator cab cannot be used to drive the mobile crane on the highway. If the operator cab could be used as the driving cab, plastic glazing could only be used in locations to rear of the driver at levels not requisite for driving visibility.

Please contact this office if you have any questions concerning this interpretation.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Ref: PSR-2727

February 23, 1978

U.S. Department of Transportation National Highway Traffic Safety Administration (NHTSA) Washington, D.C. 20590

Attention: Office of Legal Counsel

Subject: Request for Interpretation on Use of Plastic Glazing Materials on Superstructure Cabs Applicable to Mobile Hydraulic Cranes.

Reference: (a) FMVSS-205 (b) Z26.1-1966

Dear Sir:

For the past few years our distributors, predicated on user input, has requested Grove to consider the installation of various plastic glazing materials in our (upper) superstructure operator cabs to aid in the prevention of vandalism at their yards and construction job-sites as well as reducing machine "down-time" for glass replacement.

For your edification, we have included two typical carrier-mounted hydraulic crane sales brochures to be utilized as an aid to better understand our design characteristics and positioning of our superstructure cabs. Grove Manufacturing Company feels that an official interpretation from your office is required prior to any action on our part to install a glazing material other than glass inasmuch as Grove does certify to meet all Federal Motor Vehicle Safety Standards (FMVSS) on the date of manufacture.

Our interpretation of FMVSS-205 precludes the use of plastic materials as glazing other than to the rear of the driver, however, our superstructure cab is utilized strictly for craning operations on an off-highway configuration and while "roading" the crane over public highways the upper mode is unoccupied.

If clarification or further information is required to aid in forming an official NHTSA opinion on this matter, please do not hesitate to contact us.

May we thank you in advance of any consideration given in this matter.

Very truly yours,

GROVE MANUFACTURING COMPANY

R. G. Wilkins Product Safety & Reliability Analyst

RGB/cds

Encl.