Interpretation ID: nht90-4.8

TYPE: Interpretation-NHTSA

DATE: September 14, 1990

FROM: Loren Thomson -- Thomson & Weintraub

TO: Dorothy R. Nakama -- Rule Making Attorney, United States Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to Loren Thomson (A37; Std. 205; VSA 108(a)(2)(A))

TEXT:

I represent the Glass Specialty Companies. They, as well as others in the glass repair and replacement industry have concerns with the types of repair being afforded by some members of the industry and with the replacement of original equipment, automob ile glass, with substandard glass.

Edward H. Barnes, the president of Glass Specialty with whom you have talked, indicates to me that you've indicated that the Federal Motor Vehicle Standard, No. 205, is not specific upon standards with respect to the repair or replacement of automobile g lass. The only standard being that the repair or replacement must not leave the vehicle, "inoperable," or render it so.

Our position is that if a windshield or a side glass is likely to shatter or distort the vision of an operator, the vehicle is indeed "inoperable."

We would respectfully request an interpretive letter from your department of what the term "render inoperable" means in safety standard no. 205 as regards a chipped, cracked, or broken windshield.

If you have any questions on the matter, please direct them to me.