Quality Assurance Manager
500 Park Drive
Owatonna, MN 55060
Dear Ms. Reuvers:
This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, with respect to the marking of automotive glazing manufactured by two different companies. According to your letter, your company, Viracon/Curvlite, purchases bent tempered AS-2 glazing from a fabricator. Your company then laminates a piece of "SenryGlas" to the bent tempered product, thereby making it AS-15B glazing.
You asked how Viracon/Curvlite's glass-plastic glazing should be marked under S6.1 of the standard. Specifically, you asked whether there should be marking information about both the first company (the glass fabricator/temperer) and additional marking information about the second company (Viracon/Curvlite, the laminator). You believe only Viracon/Curvlite need mark the product, since the company, as the laminator, would be fully responsible for its compliance.
We agree with your assessment. Viracon/Curvlite, as the manufacturer of the tempered glass-plastic glazing, would mark the product with the AS-15B designation. The glazing would not contain the marking of the supplier of the bent tempered product.
I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.
Philip R. Recht Chief Counsel