ID: nht94-8.46

DATE: January 21, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Terry Karas -- T. K. Auto Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/5/93 from Terry Karas to John Womack

TEXT:

This responds to your FAX of November 5, 1993.

You have asked whether a Canadian car that was accompanied by a Canadian manufacturer's letter stating that the vehicle complies with U.S. safety standards can be imported as a conforming vehicle under Box 2.

Box 2 on the HS-7 importation form is the importer's declaration under 49 CFR 591.5(b) that the motor vehicle to be imported complies with all applicable U.S. Federal motor vehicle safety standards, and bears a certification label or tag to that effect, affixed by the original manufacturer of the vehicle. Because some Canadian vehicles may be virtually identical to those manufactured in the United States, and hence may comply with U.S. safety standards even if not bearing a specific certification to U.S. safety standards, the National Highway Traffic Safety Administration has accepted, in lieu of specific certification to U.S. safety standards, a letter from the Canadian manufacturer stating that the vehicle to be imported was manufactured to comply with the U.S. safety standards.

If a manufacturer's compliance letter accompanies a vehicle manufactured for sale in Canada at the time such vehicle is offered for importation into the United States, the vehicle may be entered under Box 2 as a conforming vehicle, without the intervention of a registered importer or the issuance of a bond. However, the manufacturer's compliance letter must contain the VIN of the specific vehicle that is to be imported, and an unqualified statement that the vehicle, as manufactured, complied with all applicable U.S. Federal motor vehicle safety standards.

Customs will then forward the HS-7 form and manufacturer's letter to this agency. However, if customs wishes us to review the manufacturer's letter, it is the prerogative of Customs to defer entry of the vehicle until it has received our views as to whether entry under Box 2 is appropriate.

You have also asked whether it makes "a difference if it is being imported for commercial or private purposes." Any Canadian vehicle that is accompanied by an acceptable manufacturer's letter of compliance is eligible for entry as a conforming vehicle under Box 2, regardless of whether the intent of importation is the commercial sale of the vehicle, or the retention of the vehicle for private use. However, if the letter is not an acceptable statement of compliance and the importation is for commercial purposes, the vehicle may only be imported under bond by a registered importer who must satisfy NHTSA that the vehicle complies, or has been brought into compliance, with the U.S. safety standards. Even though the registered importer's compliance work may be minimal, it is important to remember that the registered importer is also the person

responsible by statute for implementing notification and remedy campaigns in the event that noncompliances of the original manufacturer or safety related defects are discovered in the Canadian vehicle.

ID: nht93-6.15

DATE: August 16, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from Ron Marion to Marvin Shaw (OCC 8838)

TEXT:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. S 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added).

This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the DRIVER'S side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

ID: nht93-2.4

DATE: 03/03/93

FROM: BARRY FRELRICE -- ASSOCIATE ADMINISTRATOR FOR RULEMAKING, NHTSA

TO: RON MARION -- SALES ENGINEER, THOMAS BUILT BUSES, INO.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12-4-92 FROM RON MARION TO BARRY FELRICE (OCC 8073)

TEXT: This responds to your letter asking whether there has been any consideration given to excluding "non-route-type" school buses from Standard No. 131's requirement that school buses be equipped with a stop signal arm. You stated that, as a manufacturer of school bus bodies, you are getting numerous questions regarding the installation of stop arms on school buses not used on route service. According to your letter, a number of schools across the U.S. purchase school buses, paint them a color other than yellow, and use them exclusively for athletic trips. You stated that these buses pick up at the school and travel to another school to unload, and do not make stops for loading or unloading along the way and in no way attempt to control traffic. You stated that the purchasers of these school buses are concerned about paying for stop arms which are never used.

As you know, Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices, is a new Federal motor vehicle safety standard which requires all new school buses to be equipped with a stop signal arm. The purpose of the requirement is to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the bus.

To answer your specific question, this agency has not considered whether "non-route-type" school buses should be excluded from Standard No. 131's requirement for a stop signal arm. I note that this issue was not raised in the comments on our notice of proposed rulemaking.

We do appreciate the concern of a purchaser about paying for safety equipment that he or she believes will never be used. However, the limited information provided in your letter does not provide a basis for concluding that we should consider changing the standard.

We do not know how many school buses are used exclusively or primarily for "non-route-type" service, although we assume the number is small. Further, it would appear that there would be occasion to use signal arms for some school buses used for such service. For example, these safety devices might be used while loading and unloading students when the school bus is parked on a school driveway or a road near a school, if the school bus is used to transport students to activities at locations other than schools, or if the school bus is sometimes used as a replacement for out-of-service regular route school buses. T also note that, assuming that there is occasion to use stop signal arms or some school buses which are primarily used for non-route service, it is not clear how the agency would distinguish, for purposes of a regulation, which school buses should be excluded from the requirement for stop arms.

I hope this information is helpful.

ID: nht75-6.15

DATE: 10/29/75

FROM: AUTHOR UNAVAILABLE; John G. Haviland; NHTSA

TO: Laird E. Johnston -- General Motors Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Free Sliding Latch With Tension Relieving Feature

Laird E. Johnston ASE - Engineering Staff

The following comments are in reference to your question concerning whether existing safety standards allow a shoulder belt tension relieving feature on a single loop three point belt system having a free sliding (non-cinching) latch.

GM Legal Staff has been consulted concerning interpretation of the present wording in MVSS 203, Section S7.1.1 (Attachment 1) and proposed amendment Docket 74-32 Notice 1 (Attachment 2). Legal Staff and ASE agree that:

a) The current MVSS 203 does not clearly prohibit the use of a free-sliding latch plate with a shoulder belt tension relieving device but the NHTSA interprets MVSS 208 as prohibiting such a system (see Attachment 3), and

b) A proposed amendment to MVSS 208 Docket 74-32 Notice 1, does clearly limit the use of comfort devices to the upper portion of the seat belt assembly - the lap belt portion must remain individually adjustable (i.e. introducing slack into the shoulder belt should not affect the lap portion of the assembly).

In our response to Docket 74-32 Notice 1 (Attachment 4), General Motors agreed that devices to relieve tension should not be used on systems permitting inadvertent misadjustment.

ASE also has reservations about the impact performance of such a system both for adult occupants and when used in conjunction with child seats. Although limited sled tests of one such system resulted in no submarining with up to three inches of slack in the lap belt, there is no assurance that occupants would wear these systems correctly or that all similar belt configurations would perform in this manner. Additionally, GM only recommends the use of the child seat in 1968-1975 domestic made vehicles. All of these vehicles have a lap belt that permits lap belt tension independent of the shoulder belt. Present thoughts are that a separate lap belt tension holding clip will have to be supplied with the child seat if GM were to recommend its usage with a free-sliding latch single loop system.

One compromise you may wish to consider is the use of a friction device on the free sliding latch that would allow free belt transfer from the lap belt to the shoulder but hold minimal lap belt tension, possibly five to ten pounds. This should satisfy the NHTSA but would still pose some problem with improper child seat usage. Another solution, which you are aware of, is providing low shoulder belt tension thus reducing the need for a tension relieving device. A one-way cinching latch is the ideal solution to the performance and compliance questions.

If we can be of any further assistance, please let us know.

(original signed by) John G. Haviland Collision Protection/Restraints Automotive Safety Engineering JGH/rk

Attachments (4)

cc: G. F. Ball E. E. Conner T. G. Wingblad

ID: nht94-1.22

TYPE: Interpretation-NHTSA

DATE: January 21, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Terry Karas -- T. K. Auto Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/5/93 from Terry Karas to John Womack

TEXT:

This responds to your FAX of November 5, 1993.

You have asked whether a Canadian car that was accompanied by a Canadian manufacturer's letter stating that the vehicle complies with U.S. safety standards can be imported as a conforming vehicle under Box 2.

Box 2 on the HS-7 importation form is the importer's declaration under 49 CFR 591.5(b) that the motor vehicle to be imported complies with all applicable U.S. Federal motor vehicle safety standards, and bears a certification label or tag to that effect, affixed by the original manufacturer of the vehicle. Because some Canadian vehicles may be virtually identical to those manufactured in the United States, and hence may comply with U.S. safety standards even if not bearing a specific certification to U. S. safety standards, the National Highway Traffic Safety Administration has accepted, in lieu of specific certification to U.S. safety standards, a letter from the Canadian manufacturer stating that the vehicle to be imported was manufactured to comply w ith the U.S. safety standards.

If a manufacturer's compliance letter accompanies a vehicle manufactured for sale in Canada at the time such vehicle is offered for importation into the United States, the vehicle may be entered under Box 2 as a conforming vehicle, without the interventi on of a registered importer or the issuance of a bond. However, the manufacturer's compliance letter must contain the VIN of the specific vehicle that is to be imported, and an unqualified statement that the vehicle, as manufactured, complied with all a pplicable U.S. Federal motor vehicle safety standards.

Customs will then forward the HS-7 form and manufacturer's letter to this agency. However, if customs wishes us to review the manufacturer's letter, it is the prerogative of Customs to defer entry of the vehicle until it has received our views as to whe ther entry under Box 2 is appropriate.

You have also asked whether it makes "a difference if it is being imported for commercial or private purposes." Any Canadian vehicle that is accompanied by an acceptable manufacturer's letter of compliance is eligible for entry as a conforming vehicle u nder Box 2, regardless of whether the intent of importation is the commercial sale of the vehicle, or the retention of the vehicle for private use. However, if the letter is not an acceptable statement of compliance and the importation is for commercial purposes, the vehicle may only be imported under bond by a registered importer who must satisfy NHTSA that the vehicle complies, or has been brought into compliance, with the U.S. safety standards. Even though the registered importer's compliance work may be minimal, it is important to remember that the registered importer is also the person

responsible by statute for implementing notification and remedy campaigns in the event that noncompliances of the original manufacturer or safety related defects are discovered in the Canadian vehicle.

ID: nht91-6.36

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Al Lipinski -- President, Mini-Max

TITLE: None

ATTACHMT: Attached to letter dated 9-18-91 from Al Lipinski to Messrs. Hall, Jackson, and Rice, NHTSA (OCC 6509)

TEXT:

This responds to your letter asking what the dynamic testing requirements are for alterers of certified vehicles. You stated that you are a small conversion company of walk in van type light trucks, that you do not alter anything forward of the B pillar of the previously certified vehicle, and that the crash protection system installed by the original manufacturer is not disturbed. You also stated that you affix an additional label stating the vehicle alterations conform to all applicable Federal motor vehicle safety standards.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. As you are aware, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.; Safety Act), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Under NHTSA's certification regulation, an alterer is a person who alters previously certified vehicles by means other than the addition, substitution, or removal of readily attachable components, or minor finishing operations, or in such a manner that the vehicle's stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale. An alterer is required to certify that every vehicle it alters continues to comply with all applicable safety standards after the alterer has performed its operations on the vehicle. See 49 CFR Part 567.7.

Alterers must have some independent basis for their certification that an altered vehicle continues to comply with all applicable safety standards. This does not, however, mean that an alterer must conduct crash testing, even with respect to standards that include dynamic test requirements. Certifications of continuing compliance for altered vehicles may be based on, among other things, engineering analyses, computer simulations, actual testing, or instructions for alteration voluntarily provided by the original vehicle manufacturer in a "body builder's guide."

Your letter suggests that you are primarily concerned about the dynamic test requirements of Standard No. 208 Occupant Crash Protection. I note that in establishing that standard's dynamic test requirements for light trucks, NHTSA made those requirements optional for walk in van type trucks. See S4.2.2 of Standard No. 208. Thus, the walk in van type

trucks you alter were not required to comply with the Standard No. 208's dynamic test requirements and may not have been designed to do so. You can find out by contacting the original vehicle manufacturer.

I hope this information is helpful.

ID: nht95-6.1

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 5/18/95 LETTER FROM JIM BURGESS TO WALTER MYERS (OCC 10931)

TEXT: Dear Mr. Burgess:

This responds to your letter of May 18, 1995 to this office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system.

You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no.

FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states:

Side doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not conform to this standard.

FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion.

While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that "lift" includes "ramp." In order to amend the standard to exclude wheelchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriate.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ID: nht95-3.77

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 5/18/95 LETTER FROM JIM BURGESS TO WALTER MYERS (OCC 10931)

TEXT: Dear Mr. Burgess:

This responds to your letter of May 18, 1995 to this office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door rete ntion components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system.

You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no.

FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states:

Side doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not confo rm to this standard.

FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion.

While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that "lift" includes "ramp." In order to amend the standard to exclude whe elchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriat e.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ID: nht68-1.39

DATE: 02/20/68

FROM: H. S. BEAGLE -- ELECTRICAL TESTING LABORATORIES, INC.

TO: EDWIN L. SLAGLE -- NATIONAL HIGHWAY SAFETY BUREAU FEDERAL HIGHWAY ADMINISTRATION DEPARTMENT OF TRANSPORTATION

COPYEE: J. R. SCHAEFFER -- ETL; A. R. CHICK -- ETL

TITLE: MOTOR VEHICLE SAFETY STANDARD NO. 205 -GLAZING MATERIALS

REF.1: ELECTRICALLY HEATED SAFETY GLASS FOR DEFOGGING

REF.2: TEST PROCEDURE PER USA STANDARD 226.1-1966

ATTACHMT: LETTER DATED 2/21/68 FROM EDWIN L. SLAGLE OF D.O.T. NATIONAL HIGHWAY SAFETY BUREAU TO H. S. BEAGLE OF ELECTRICAL TESTING LABORATORIES INC.

TEXT: The above subject reference No. 2 provides, in part, that safety glazing material be tested for regular (parallel) luminous transmittance (method unspecified), which value shall be not less than 70 per cent both before and after irradiation (ultraviolet are exposure). The word "parallel" means that the light beam used in making this measurement should be essentially collimated. This condition may be obtained by using a light source sufficiently distant from the test specimen that the rays are essentially parallel.

Our photometric laboratory has been performing this test satisfactorily for many years, using the apparatus shown in the attached photographs numbered 1 through 4, as follows:

Photo #1 - A general view, no glass in place, showing diaphragm plate and source of collimated beam above. Light source, positioned 48 inches above photo cell and shielded, is an incandescent monoplane tungsten-filament lamp calibrated for operation at the specified color temperature of 2854 degrees Kelvin.

#2 - Close up of diaphragm plate with 1-1/4-inch opening, positioned 3/4 inch above the color corrected photovoltaic cell. Cell is visible through diaphragm opening.

#3 - Set-up with glass specimen in place. Glass specimen shown has electrically conductive lines on one surface.

#4 - Close up of glass specimen on diaphragm plate.

In performing this measurement the test specimen is moved laterally across the diaphragm (aperture) to find and record the minimum transmittance value.

2

It is our belief that this test method is as suitable for evaluating the luminous transmittance of electrically heated safety glass as it is for the same glass not so treated. As a matter of fact, it has been so employed in the past with respect to imported glass of the electrically heated type.

However, to avoid possible future problems concerning the acceptability of our test method, we are submitting this matter for your consideration at this time. The urgency of it is related to the long loud time with respect to production of electrically heated safety glass to provide for defogging of rear windows in motor vehicles.

We therefore respectfully ask for your written approval of the test method, as herein described, as being acceptable for purposes of evaluating the luminous transmittance of electrically heated safety glass for compliance in this regard, with the requirements of MVSS No. 205.

The earliest possible response to this request would be most sincerely appreciated.

Sincerely yours,

Enclosure: photographs

ID: nht70-1.43

DATE: 02/25/70

FROM: AUTHOR UNAVAILABLE; F. C. Turner; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: RE: PETITION FOR RULEMAKING

This is in reply to your letter of October 16, 1969, requesting an exception from Paragraph S3.1 of Federal Motor Vehicle Safety Standard No. 205 ("Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses"), to allow the use of Lemen and Plexiglas in certain specified locations in twenty-one (21) fire fighting vehicles to be delivered to the city of New York.

You state the purpose of your request is to provide better protection for occupants of these fire fighting vehicles from objects thrown at them when, for example, the vehicles are enroute to a fire. Further, you state the use of these materials would eliminate replacing safety glass, which can be broken when hit by small objects. Because you are requesting a change in an existing standard your letter has been treated as a petition for rulemaking to amend Standard No. 205, pursuant to the provisions of 49 CFR @@ 353.31, 353.33. For the reasons stated below, your petition is denied.

It is not completely clear from your letter and the enclosed drawing where the interior or canopy partitions in which you wish to use Lexen and Plexiglas are located. Standard No. 205 presently permits the use of rigid plastics in interior partitions of fire fighting vehicles if these materials meet the requirements for plastics designated AS4 and AS5 (the latter can only be used when not requisite for driving visibility) in American Standards Association Test Z26.1-1966, July 15, 1966. We understand that Plexiglas meets these requirements and may therefore be used in this location. We also understand, however, that Lexen does not, failing specifically to meet certain chemical and abrasion resistance requirements applicable to AS4 and AS5 rigid plastics under the Standard. If our understanding regarding Lexen is correct, we believe its failure to meet these minimum requirements renders its unsuitable for use in areas of motor vehicles where a possible loss of transparency may affect the safe operation of the vehicle.

With reference to glazing in side and door windows of fire fighting vehicles, Standard No. 205 allows the use of glazing specified AS1, AS2, and AS10 in ASA Test-226.1-1966 and also allows the use of AS11 and AS3 glazing at levels not requisite for driving visibility. This glazing may be either laminated, tempered, or bullet resistant safety glass meeting the applicable requirements. Plastics meeting AS4 and AS5 requirements, while appropriate for certain locations such as partitions, are not considered appropriate for use in side and door windows as they do not possess chemical and abrasion resistance qualities necessary for exterior glazing and which the types of safety glass specified above possess. The occupant protection which you desire can be provided by using AS10 (and AS11 where appropriate) bullet resistant glass which contains both structural advantages over normally used safety glazing and satisfactory chemical and abrasion resistance for use in side and door windows.