Interpretation ID: 1982-1.17

TYPE: INTERPRETATION-NHTSA

DATE: 02/18/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Consumer and Technical Affairs, Woodhill Permatex

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter concerning a product you manufacture which is used to repair breaks in automobile windshields. You ask whether such a repair product would conflict with any present motor vehicle safety standards.

The National Highway Traffic Safety Administration has issued Federal Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair product such as you describe, however. There is no Federal regulation which would prohibit the use of such a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new windshield which may require repair as a result of damage sustained, for example, in shipment could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, which would be the responsibility of the person selling the windshield. Therefore, we do not recommend use of windshield repair kits prior to the first purchase of a new windshield by a consumer.

Please contact Hugh Oates of my staff if you have any further questions.

Sincerely,

ATTACH.

January 26, 1982

Legal Counsel -- National Highway Traffic Safety Administration

Dear Sir:

We are manufacturers and marketers of maintenance, service and repair products for the professional and the do-it-yourselfer for use around the home and in the repair of vehicles.

It has come to our attention that there exists a need to develop a product to repair stone damaged and bulls eye breaks in automobile windshields.

My question is whether or not such a repair product would conflict with any present motor vehicle safety standards.

Your prompt counsel would be appreciated since we are beginning to formulate plans for our next fiscal year.

Very truly yours, Robert J. Carter -- Director, Consumer and Technical Affairs, WOODHILL PERMATEX