Interpretation ID: 1982-3.6

TYPE: INTERPRETATION-NHTSA

DATE: 09/27/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: New York City Transit Authority

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Donald J. Cameron Director - Technical Support New York City Transit Authority 25 Jamaica Avenue Brooklyn, New York 11207

Dear Mr. Cameron:

This responds to your recent letter asking whether the driver's side window and the front entrance door window of a bus may be equipped with plastic glazing. You desire to use plastics because of the high operating cost of replacing broken glass windows.

The answer to your question is no. Safety Standard No. 205, Glazing Materials, was amended in 1977 to permit the use of rigid plastic glazing in all doors and windows of buses, except windshields or windows to the immediate right or left of the driver(42 FR 61465). The reason for this exception is that windows to the immediate right and left of the driver are necessary for driving visibility and typical plastic material used alone is not sufficiently resistant to abrasion. Plastic glazing would not be allowed in a bus entrance door since this would constitute a "window to the immediate right" of the driver. Plastic glazing would be allowed in the rear emergency door, however, if that door was not necessary for driving visibility.

You also ask whether material other than safety glass may be used in either of these locations. I am not sure that I correctly understand your question. If by "other materials" you mean, for example, sheet metal, the answer to your question would be yes. There are no Federal requirements specifying that a vehicle have windows in a certain location. Thus, theoretically, there would be nothing to preclude the installation of a solid metal entrance door in a bus. (Obviously, no manufacturer would likely do this because it would compromise driver vision.) If, however, there is a window and it is equipped with traditional glazing materials, the glazing must be in compliance with the performance and location requirements of Standard No. 205. If I have misunderstood your last question, please contact Hugh Oates of my staff and he will clarify the requirements for you (202-426-2992).

Sincerely,

Original Signed By Frank Berndt Chief Counsel

National Traffic and Highway Safety Administration Department of Transportation Office of the Chief Council 400 Seventh Street South West Washington, D.C. 20590

Greetings:

Reviewed of the Automotive Safety Glazing Materials Standard #205 and the 2-25 document, has caused the Technical Support Department some confusion in its interpretation. Your assistance in clarifying the following points would be greatly appreciated.

Replacement of glass on New York Transit Coaches is a major item in our operating costs. My questions are in regard to the driver's side window (immediate left of driver), and the front entrance door glass. Can either of the above-mentioned items be replaced with plexiglass (plastic)? Can material other than safety glass be used in either of these locations?

Thank you for your attention. We look forward to your reply.

Sincerely,

Donald J. Cameron Director - Technical Support