Interpretation ID: nht79-3.34

DATE: 06/18/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cars & Concepts, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 21, 1979, letter concerning the marking requirements for vehicle windshields having shade bands. You asked whether the "A S1" marking symbol required by Safety Standard No. 205, Glazing Materials, can be placed on the tint band itself rather than on the glazing material below the band, if the tint band is a flexible sheet applied on top of the glazing.

Safety Standard No. 205 incorporates by reference the American National Standard "Safety Code for Safety Glazing Materials", ANS Z26. The ANS Z26 standard requires special additional markings for glazing that has shade bands or tinted areas:

"Glazing materials, which in a single sheet of material, are intentionally made with an area having a luminous transmittance of not less than 70 percent (Test No. 2), adjoining an area which has less than 70-percent luminous transmittance, shall be permanently marked at the edge of the sheet to show the limits of the area which is intended to comply with Test No. 2. The markings shall be A S1 or A S2, etc., the direction of the arrow indicating the portion of the material which complies with Test No. 2 and the number indicating the item with which that portion of the sheet complies . . . ."

You will note from the quoted portion of this specification that the special marking is only required if the tinted shade band area of the windshield has a luminous transmittance of less than 70 percent. Your letter states that the transparent windshield tint band that you intend to use allows 70 percent light transmission. Therefore, you would not be required to use the "A S1" special marking either on the band itself or on the glazing.

For removable tint bands of this type that do not have a 70 percent light transmission, however, the agency would permit the "A S1" marking to be on the tint band itself rather than on the underlying glazing, provided the marking is located at the lowest possible portion of the tint band.

Sincerely,

ATTACH.

May 21, 1979

Joseph J. Levin -- Chief Council, N.H.T.S.A.

Dear Mr. Levin:

Cars & Concepts is preparing a vehicle for 1980 production which incorporates a transparent windshield tint band. This band would allow 70% light transmission across its width and be located in accordance with SAE J-100.

This band would be applied to a piece of untinted glass and this condition forms the basis for my question. If we install a shade band across the top of a vehicle's windshield, are we required to sandblast the designation "AVSI" onto the glass below the band (I understand it is cited through reference in FMVSS No. 205)?

If this "AVSI" notice is required on untinted glass when a shade band is applied, I propose that it should be on the band itself as it is only when the band is on the car (it would be possible to remove the band) that this notice is required.

The N.H.T.S.A.'s decision on this point is critical to our project timing as brochure shots are scheduled and the addition or deletion of this component must be made prior to brochure release. Because of this your response as soon as possible will be greatly appreciated.

Enclosed is a photograph of a vehicle with a prototype version of the mentioned tint band which I feel may clarify our question. Please call if any point is unclear.

Sincerely, Moe Pare -- Director of Design

Encl.

cc: D. Draper; R. Ryan

(Graphics omitted)