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Interpretation ID: PFTF142.TMP



    Mr. Tim Peffley
    Manager of Quality Systems and Engineering
    SpecTemp, Inc.
    5406 U.S. Rt. 24
    Antwerp, OH 45813


    Dear Mr. Peffley:

    This responds to your January 23, 2001, letter regarding the use of laminated glass for AS2 and AS3 locations.

    You state in your letter that you are writing on behalf of your company, SpecTemp, Inc. (SpecTemp) which is a glass fabricator and temperer servicing an array of different industries. You ask about a lamination technique developed by UCB Chemical Corp. which creates a laminated unit by using a liquid resin application technique. More specifically, the glazing produced by this technique consists of two sheets of glass held together by a liquid resin which, when cured, will provide adhesive strength as a glass laminate.

    SpecTemp is seeking from this office a letter that "interprets and condones using laminated, fully tempered safety glass lites, as a unit, in AS2 and AS3 vehicle locations." Further you ask 1) whether there are special tests that must be conducted, outside of your normal DOT testing, for laminated glass that will be used in AS2 and AS3 vehicle locations, 2) whether you must designate any special markings when using laminated glass in side lite installations, and 3) whether you can use your current DOT etch designation. As explained below, outside of the performance, location, labeling, and certification requirements contained in this agency's glazing standard for the type and location of glazing described above, no "special tests" or "special markings" exist. Furthermore, you may use your current DOT etch designation for this glazing provided that it was assigned by this agency pursuant to the glazing standard requirements.

    By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment.

    Federal law establishes a self-certification system under which motor vehicle and equipment manufacturers themselves certify that their products comply with all applicable standards. For that reason, NHTSA neither endorses, approves, nor conducts testing of products prior to their introduction into the retail market. Rather, we enforce compliance with the standards by purchasing vehicles and equipment and testing them. We also investigate safety-related defects. I will now address the specific questions raised in your letter.

    First you ask whether there are special tests that must be conducted outside of your normal testing for laminated glass that will be used in AS2 and AS3 locations. The answer is no. Pursuant to NHTSA's authority, the agency has established FMVSS No. 205, Glazing Materials (49 CFR 571.205). FMVSS No. 205 incorporates by reference "ANS Z26," the American National Standards Institute's Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways. FMVSS No. 205 and ANS Z26 specify performance requirements for various types of glazing (called "Items"), and specify the locations in vehicles in which each item of glazing may be used. (In your letter, you incorrectly identified the codes AS2 and AS3 as "vehicle locations." Those designations are codes required on glazing materials by section 6 of ANS Z26.) Your company's product, a laminated glass, may be used in the vehicle areas designated for Item 2 and/or Item 3 glazing subject to its meeting the prescribed tests for those Items contained in FMVSS No. 205.

    Your second and third questions ask whether you must designate any special markings when using laminated glass in side lite installations, and whether you can use your current DOT etch designation. No "special markings" requirements exist for the glazing you describe, and you may continue to use your manufacturer code mark assigned by DOT. (In your letter, you incorrectly refer to the manufacturers code mark as a "DOT designation.") However, you must comply with the marking and certification requirements set forth in S6 of FMVSS No. 205.

    For your further information, I am enclosing a fact sheet we prepared entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and Where to Obtain NHTSA's Safety Standards and Regulations.

    I hope this information is helpful. If you have any questions or need additional information, feel free to contact Nancy Bell of my staff at (202) 366-2992.

    Sincerely,
    John Womack
    Acting Chief Counsel

    Enclosure
    ref:205
    d.6/22/01