Interpretation ID: aiam3249
Morgan
Lewis & Bockius
1800 M Street
N.W.
Washington
D.C. 20036;
Dear Mr. Masterson: This responds to your recent letter requesting an interpretation o Safety Standard No. 205, *Glazing Materials* (49 CFR 571.205). You ask whether the abrasion test for vehicle windshield glazing must be conducted on both the exterior and interior surfaces of the windshield.; Your letter states that the 'Securiflex Inner Guard Windshield' wit which you are concerned consists of typical windshield glazing with an added layer of clear plastic bonded to one surface, which protects occupants from contact with shattered glass from the outer surface. Apparently, this interior plastic surface cannot pass the abrasion test required for windshield glazing.; Section 4 of the 'ANS Z26' standard which is incorporated by referenc in Safety Standard No. 205 specified that glazing material for use as vehicle windshields must comply with the tests indicated for 'Item 1' glazing, which includes abrasion Test 18. Footnote number 3 under the specifications for 'Item 1' glazing provides that 'multiple glazed units shall be tested on both sides using separate specimens for each side.' Therefore, both the interior and exterior surface of a vehicle windshield must comply with abrasion Test 18. We believe that this is a necessary requirement, for both the abrasion test and the other tests specified for 'Item 1' glazing. While the 'Securiflex' windshield might have sufficient abrasion resistance on the interior surface to prevent distortion of a driver's vision, manufacturers would be allowed to develop interior surfaces which had absolutely no abrasion resistance if only the exterior surface of the windshield is required to be tested.; This is not to say that a somewhat less stringent abrasion resistanc requirement for the interior surface of a windshield like the 'Securiflex' is not in order, if the safety advantages of this type glazing outweigh the potential problems of abrasion. However, for this to be allowed Safety Standard No. 205 would have to be amended to specify separate abrasion resistance requirements for the exterior and interior surfaces of multiple glazed windshields. Therefore, I suggest that you submit a petition to amend the standard and supply all necessary supporting data and information. I realize that you are concerned with the amount of time this would require, but such a distinction in the requirements cannot be accomplished by interpretation. The agency would have to consider the disadvantages that might result from a reduction in the abrasion resistance requirements, as well as determine what increase on performance in other test would be required before such a reduction would be allowed.; This letter should in no way be considered a disapproval of th 'Securiflex' windshield. The information supplied in your letter certainly indicated that this windshield design is an advance in motor vehicle safety. If this is in fact the case, the agency will make every attempt to encourage the use of similar designs.; Sincerely, Frank Berndt, Chief Counsel