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Interpretation ID: nht93-7.41

DATE: October 26, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard Campfield -- President, Ultra B-O-N-D. Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/22/93 from Richard Campfield to John Womack or Marvin Shaw

TEXT:

Thank you for your letter in which you address the repair of motor vehicle windshields. You explain that, as president of a window repair business, you are concerned with recent actions taken by the window replacement industry to form a committee to set a voluntary "standard" for window repair. According to your letter, the anticipated standard will be "archaic in its structure" because the committee is "prejudicial," in that virtually all the committee's members are in the windshield replacement industry. You contend that the effort to adopt the standard is intended to reduce competition from the window repair industry. You request that NHTSA recommend ways to prevent the window replacement industry from enacting the industry standard.

We read your letter with great interest. However, industry groups are free to adopt any voluntary standard they believe is appropriate for their needs. NHTSA does not become involved with the adoption of voluntary standards unless a voluntary standard raises safety issues that the agency ought to address. We are unaware of safety issues pertaining to the voluntary standard you described. While we are not aware of safety problems with the bonding process you describe, we do not have information to support your claims or those of your competitors.

Nevertheless, to keep our information on window glazing current, we will keep your letter on file in NHTSA's public docket dealing with Standard No. 205, Glazing Materials (49 CFR S571.205). In addition, the agency's engineers have been briefed on the issues you raise in your letter.

I hope this has been helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.