Interpretation ID: nht95-1.67

TYPE: INTERPRETATION-NHTSA

DATE: February 14, 1995

FROM: Tamera Reuvers -- Quality Assurance Manager, Viracon/Curvlite

TO: Philip Recht -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO TAMERA REUVERS (A43; STD. 205)

TEXT: Mr. Recht,

I am respectfully requesting an official ruling/interpretation of 49 CFR Ch. V (10-1-91 Edition) section 571.205 Standard No. 205, Glazing materials. The section in question is section S6. Certification and marking, S6.1 states "Each prime glazing mate rial manufacturer, except as specified below, shall mark the glazing materials it manufactures in accordance with section 6 of ANSI Z26. The material specified in S5.1.2.2 . . . . shall be identified by marks AS 11C, . . . . respectively. A prime glazi ng material manufacturer is one who fabricates, laminates, or tempers the glazing material." Below is our scenario:

We purchase bent tempered product from fabricator "X", which is standard AS-2 designation material according to ANSI Z26. We laminate a piece of SentryGlas tm to the bent tempered product. This now will make the material an AS-15B designation according to ANSI Z26. My question is how should this product be properly marked. Should the primary tempered supplier, fabricator "X", have their marking (AS-2, model number and DOT number) on the product in addition to our marking (AS-15B, model number and Do t number)?

I have never seen a piece of automotive glass with two markings on it. I understand, if we only put our designation on the product, we will be fully responsible for the product. Would it be appropriate to have both prime manufacturers markings on it?

With any inquiries, please feel free to contact me. My hours are 7:00 am to 4:00 pm Monday through Friday. My number is 800-533-0482 Ext. 373.

Immediate attention to this matter would be greatly appreciated.