Interpretation ID: nht87-1.33
TYPE: INTERPRETATION-NHTSA
DATE: 02/20/87
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Bruce Torrey -- Product Performance Specialist, General Electric Company
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Bruce Torrey Product Performance Specialist General Electric Company One Plastics Avenue Pittsfield, MA 01201
Thank you for your letters of August 13, and 26, 1986, concerning how the requirements of Standard No. 205, Glazing Materials, apply to glazing materials installed in the side windows of some New York City Transit Authority (NYCTA) buses. As explained be low, the information you provided in your letters and in your phone conversations with Stephen Oesch of my staff and the information provided by NYCTA in a June 19, 1986 letter to the agency indicates the glazing materials installed in the NYCTA buses do not comply with the marking requirements of the standard.
You explained in your letter that the glazing material used in the side and standee windows in the buses is Lexan sheet, which is a plastic material manufactured by General Electric. According to your letter, the Lexan glazing material used in these wind ows can meet all of the performance requirements set in Standard No. 205 for "AS-5" glazing materials. However, the material apparently was not marked as "AS-5" material, but may have instead been marked "AS-4/6." (Information provided to the agency by t he NYCTA in June 1986 indicates that the windows did not contain any "AS" number. At the time of your phone conversation with Mr. Oesch, you had not been able to confirm what markings, if any, had been placed on the glazing material by General Electric).
Standard No. 205 specifies performance and location requirements for glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as "items" in the standard): Plastic glazing materials, such as Lexa n, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set for AS-5 glazing materials, it can be used in any window in a bus, except for the windshield, windows to the immediate right and left of the driver and the rearmost windows if used for driving visibility.
In addition to setting performance requirements for different items of glazing, the standard requires glazing materials to contain certain markings. The marking requirements of S6 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked pith the AS number (which indicates that the material meets the performance requirements set for that "item" of glazing material), a model number and the man ufacturer's logo. The information the agency has received about the markings on the glazing installed in the NYCTA buses indicates that the glazing does not have an AS number marked on it.
Any glazing sold for use in a motor vehicle must conform to the applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, General Electric is required by Part 573 of our regulations to file a report with the agency providing additional details about the noncompliance and General Electric's plans to remedy the noncompliance. As you requested of Mr. Oesch, I am also enclosing a copy of the agency's regulation concerning the filing of a petition for a determination t hat a noncompliance is inconsequential.
If you have any further questions, please let me know.
Sincerely,
Erika Z. Jones Chief Counsel Enclosures
August 26, 1986
Office of the Chief Council National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590
Re: Letter from General Electric Company - August 13, 1986
Gentlemen:
In reference to my letter dated August 13, 1986 concerning the incorrect marking of glazing materials a matter of some urgency has come to my attention. It seems that the New York City Transit Authority is exercising exceptional prudence with regard to t his matter. If this situation continues hundreds of thousands of dollars worth of perfectly good material will be excluded from use.
It would be greatly appreciated if you could respond to the following.
Mr. William Wallace New York City Transit Authority 25 Jamaica Avenue Brooklyn, NY 11207
Mr. R.J. Watters Commercial Plastics & Supply Company Transportation Division 1620 Woodhaven Drive Cornwells Heights, PA 19020
If you have any questions or concerns please feel free to contact me. I can be reached at (413)448-7629. I thank you in advance for you cooperation.
Regards,
Bruce M. Torrey Product Performance Specialist
August 13, 1986
Office of the Chief Council National Highway Traffic Safety Administration 400 7th Street S.W. Washington, D.C. 20590
Re: Incorrect Glazing Marking
Gentlemen:
In order to satisfy the Department of Transportation in New York City I need an official statement concerning the following matter.
Lexan sheet, manufactured by General Electric Company is a plastic (polycarbonate) material typically used for bus side windows and standee glazings. These products are tested per ANSI Z26.1 standards on a regular basis and submitted to AAMVA for verific ation and certification.
During this process our Lexan@ MR-5000 Bronze tinted material was assigned an AS 4/6 designation, as it appears on the Notice of Equipment Compliance from AAMVA. Apparently a misinterpretation of ANSI Z26.1 test NO. 2 which requires minimum light-transmi ssion value of 70%. (1/4" Bronze Lexan@ MR5000 has a value of 53%).
Instead of being appropriately marked, AS-5, they received the AS 4/6 marking.
The following, details pertinent information.
Material Distributor:
Commercial Plastics & Supply Corp. Transportation Division 1620 Woodhaven Drive Cornwells Heights, PA 19020
Bus Manufacturer:
Blitz Bus & Truck 4525 W. 26th Street Chicago, IL 60623
This particular situation involves some 3,000 side windows and another 390 standee windows.
Enclosed you will find supporting test data and a copy of our original Notice of Equipment Compliance.
If you have any questions please feel free to contact me. I can be reached at (413)448-7629.
Regards,
Bruce M. Torrey
Enclosures Omitted.