Interpretation ID: nht95-3.26

TYPE: INTERPRETATION-NHTSA

DATE: June 26, 1995

FROM: Jerel M. Sachs -- General Manager, Automotive Glass, Import Products Glass

TO: Clarke Harper

TITLE: NONE

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO JEREL M. SACHS (A43; REDBOOK 2; STD. 205); ALSO ATTACHED TO 8/4/86 LETTER FROM ERIKA Z. JONES TO HENRY A. GORRY; ALSO ATTACHED TO 6/10/87 LETTER FROM ERIKA Z. JONES TO DAVID C. MAROON; ALSO ATTACHED TO 6/14/90 LETTER FROM PAUL JACKSON RICE TO NORMAND LAURENDEAU

TEXT: Dear Clark:

Thank you for returning my telephone call today. Pursuant to our telephone conversation I would like to state that Import Products Company is a prime glazing manufacturer and distributor. Our new address as of August 1st, 1995 will be; 55 Stockland Blv d., Bridgewater, MA 02324.

We intend to engage in the manufacture and/or contract manufacture of automotive safety glass in the United States and overseas. We are in the process of negotiations for the tooling and machinery of Lin's Glass Company who currently hold DOT # 396 and manufacture under the brand name of Sunmat. Part of the negotiation is acquiring the Sunmat brand name and corresponding DOT # 396.

I will contact you as soon as I know more about the release of the DOT # 396/ Sunmat name. In the meantime, please confirm acceptance of this letter but hold off assigning us a DOT number. Thank you for your help.

Enclosure (follow up letter)

July 13, 1995

Paul Atelsek Chief Council's Office 400 7 Street SW Washington, DC 20590

Dear Paul:

Per our telephone conversation yesterday 1 am faxing you a copy of the letter I sent to Clark Harper on June 26, 1995. As discussed, I see great merit for both NHTSA and our company in holding a D.O.T. number since we will be doing contract manufacturin g with a supplier who is also supplying other customers. This will help us monitor quality control and track our product in the marketplace.

Import Products Company has been in business for over 28 years and has been involved in the importing, contract manufacturing and distribution of automotive parts for use in the United States and export. We are experienced in doing voluntary recalls for quality control problems of automotive products that are unrelated to safety. I am sure that you must agree that NHTSA would have a much better chance working with IPG to implement a recall as compared to a company overseas in Taiwan, Malaysia or China through an Agent for Service of Process, which in many cases is a family relative or friend of somebody who works in the factory. Overall, I see this as a win-win combination for all of us and I hope you agree.

I look forward to hearing from you soon. Thank you.

Sincerely,

Jerel M. Sachs General Manager Automotive Glass, IMPORT PRODUCTS GLASS

cc: Clark Harper