Interpretation ID: 10947-1

Giuseppe Di Vito
Societa Italiana Vetro S.p.A.
Sede e Stabilimenti
66050 San Salvo (Chieti)
Zona Industriale

Dear Mr. Di Vito:

This responds to your May 22, 1995, letter requesting an interpretation regarding the testing requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, "Glazing Materials." I apologize for the delay in responding. You stated in your letter that you have been requested to manufacture for BMW some type 15A side window security glazing with an internal spall shield coating. Because of the adhesive with which it is applied, this coating cannot pass test number 4 of ANSI Z.26.1-1977 (the boil test). Nevertheless, you urge that test number 5 (the bake test) be used as a substitute for purposes of compliance certification.

The boil test and the bake test are not equivalent, and your glazing would have to meet the boil test. Although both tests subject the glazing to the same heat for the same period, the bake test applies the heat using an oven, whereas the boil test applies the heat using boiling water. Section 5 of Z.26 explicitly states that the boil test is to be used for safety glass and that the bake test is only to be used for multiple glazed units. The illustrations that you enclosed with your letter show that your glazing is not a multiple glazed unit. Therefore, it has to meet the boil test to be certified for use on motor vehicles sold in this country.

I hope this information is helpful. If you have any further questions or need additional information, please feel free to write Paul Atelsek of my staff at this address or call him at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:205 d:8/4/95