Interpretation ID: aiam4255
Assistant Manager
Chemical Commodities
New York City Transit Authority
25 Jamaica Avenue
Brooklyn
NY 11207;
Dear Mr. Wallace: Thank you for your letter of June 19, 1985, concerning how ou regulations would affect the use of certain glazing materials in buses. You explained that the Transit Authority has recently contracted to have several hundred buses rehabilitated. As a part of that work, the side glazing of the buses was replaced with glazing that contained the following markings, 'Lexan, MR 5000 sheet, ANSI Z 26-1, Camplas, NY.'; Subsequent to receipt of your letter, we received additiona information from General Electric, the manufacturer of Lexan, concerning the glazing material used in the side windows of your buses. According to General Electric, the Lexan glazing material used in these windows can meet all of the performance requirements set in Standard No. 205 for 'AS-5' glazing materials. The glazing material apparently was not marked as 'AS-5' material. As discussed below, if the only markings on the glazing are the markings you described in your letter, the glazing apparently does not comply with the marking requirements of Standard No. 205, *Glazing Materials*.; Standard No. 205 specifies performance and location requirements fo glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as 'items' in the standard.) Plastic glazing materials, such as Lexan, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set for AS-5 glazing materials, it can be used in any window in a bus, except for the windshield, the windows to the immediate right and left of the driver, and the rearmost windows, if used for driving visibility.; In addition to setting performance requirements for different items o glazing, the standard requires glazing materials to contain certain markings. The marking requirements of S6 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked with the AS number (which indicates that the material meets the performance requirements set for that 'item' of glazing material), a model number and the manufacturer's logo. The information you provided about the markings on the glazing installed in your buses indicates that the glazing does not have an AS number marked on it.; Any glazing sold for use in a motor vehicle must conform to th applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, we have been in contact with General Electric to obtain further information about this possible noncompliance. Our regulations do not preclude the Transit Authority from operating a vehicle with noncomplying glazing materials, however, you should check with State authorities to determine the effect of New York law on operating these buses.; Thank you for bringing this matter to the attention of the agency. I you need further information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel