Interpretation ID: nht94-4.59

TYPE: INTERPRETATION-NHTSA

DATE: October 24, 1994

FROM: Bryan J Williams -- Director, International Operations, Red Spot Paint And Varnish Co., Inc.

TO: Taylor Vinson -- Office Of Chief Counsel, NHTSA

TITLE: REF: Request For Written Interpretation / FMVSS108 and AAMVA Listing

ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO BRYAN J. WILLIAMS (A42; REDBOOK 2; STD. 108)

TEXT: Red Spot Paint & Varnish Co. Inc. is a manufacturer of specialty coatings for plastics. Our major market is for automotive applications; one of which is UV Curable SRC coatings for polycarbonate headlamp lenses. These products (specifically UVT200) pro vide abrasion resistance properties as well as protecting the plastic lens from the deleterious effects of outdoor exposure.

UVT200 has approvals from Ford Motor Company, General Motors and Chrysler Corporation for application on polycarbonate headlamp lenses to Specifications ESB-M80J-3A, MG5060 and MS-PP5-5 respectively. The coating was approved following the completion of 3 year Florida and Arizona weathering; measurements indicating the coating's conformity to the standards of SAEJ576(c) [1970] ref: chromaticity, haze, luminous transmittance and appearance were performed by the Red Spot Test Laboratory (which has "Self C ertifying" status from these US automakers.) The coating is currently being used in production at finishers for all three of these OEMs; there have been no questions about the "acceptability" of this coating on polycarbonate from any US State or Territor y.

I have received several requests from overseas headlamp manufacturers (potential users of UVT200) with respect to the fact that UVT200 does not appear on the American Association of Motor Vehicle Administrators (AAMVA) "Listing of Acceptable Plastics for Optical Lenses and Reflectors Used on Motor Vehicles."

The question for which written interpretation is requested is as follows:

Must a coating for plastic (polycarbonate) headlamp lenses appear on the AAMVA "Listing . . ." in order to meet the requirements of FMVSS108?

The perception exists among overseas headlamp manufacturers that AAMVA Listing of a coating is required by Federal Law . . . that appearance on this list is a prerequisite for the certification to FMVSS108 standards.

Your written comments clarifying the status of AAMVA (and their "Listing . . ." publication) and its relationship to Federal Motor Vehicle Safety Standards are requested.

Please respond via facsimile to (812) 467-2388 to my attention.

Thank you for your attention to this matter and I shall await your response. If you have questions or find issues which require further clarification, please contact me directly: Bryan J Williams

Director, International Operations

Red Spot Paint & Varnish Co. Inc.

1111 East Louisiana Street

Evansville IN 47711

P: (812) 428-9192

F: (812) 467-2388