Interpretation ID: nht81-3.47

DATE: 11/30/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: G & C Mills Plastics, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: It has come to our attention that you are distributing auxiliary wind deflectors for use on motor vehicles which may not be in compliance with Federal Motor Vehicle Safety Standard No. 205, Glazing Materials. You received a letter from this agency dated July 13, 1979, and a later letter from the Department of Commerce which may have misled you concerning your responsibilities for complying with Standard No. 205.

This matter was brought to our attention by Mr. Paul Hingtgen who told the agency you had shown him the correspondence referred to above. I am enclosing copies of two letters we sent to Mr. Hingtgen which explain why and how the previous letter to you from this agency was misleading. From those letters, you will see that auxiliary wind deflectors are considered to be pieces of "motor vehicle equipment" and, as such, they must be made from glazing materials that are in compliance with Standard No. 205. We hope you will ensure that any wind deflectors you sell or distribute are in compliance with the standard, since you could be subject to substantial civil penalties if you fail to do so. I am also enclosing a copy of Standard No. 205.

If after reviewing the enclosed letters you have any questions, please contact Mr. Hugh Oates of my staff (202-426-2992).

ENCLS.