Interpretation ID: aiam2757
Vice President
O Sullivan Corporation
P.O. Box 603
Winchester
VA 22601;
Dear Mr. Evans: This is in reply to your letter of February 3, 1978, to Mr. Guy Hunte of my staff, requesting assignment of a DOT' code number for purposes of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, *Glazing Materials*. You state that you supply vinyl plastic sheeting to your customer who, in turn, laminates and polishes this sheeting for use as glazing in the rear window opening of convertibles.; Under paragraph S6 of FMVSS No. 205 (a copy was previously mailed t you), the assignment of a code number is restricted to prime glazing material manufacturers. Prime glazing material manufacturers are those who either fabricate, laminate, or temper the glazing material. Since you merely supply the material to your customer who then laminates and polishes it for use as glazing, you are not considered the prime manufacturer and assignment of a code number to you is not appropriate. Your customer is the prime manufacturer in this case and it is his responsibility to certify that his glazing meets the requirements by the means specified in FMVSS No. 205.; If I can be of further help, do not hesitate to contact me. Sincerely, E. T. Driver, Acting Associate Administrator for Rulemaking