Mr. B`rje Kukka
Humalistonkatu 5
00250 Helsinki
FINLAND

Dear Mr. Kukka:

This responds to your request for an interpretation whether NHTSA's statutes and regulations would apply to a process you intend to market, in which two horizontal parallel grooves are etched into the lower portion of motor vehicle windshields. The groves apparently facilitate windshield cleaning by scraping water and debris off the windshield wipers as the wipers pass over the grooves. You provided a videotape on the process and a portion of a windshield etched with the grooves.

I am enclosing two interpretation letters, one dated March 1, 1985 and another dated October 28, 1988, both addressed to Mr. Andrew P. Kallman of Lansing, Michigan. Mr. Kallman asked NHTSA's opinion of a process that is very similar to your process. The letters explain how NHTSA's regulations would apply if your process were used on new vehicles or windshields and on windshields of a used vehicle.

Please also note, NHTSA has no authority to "approve" or certify your process. If you understood any previous correspondence from agency personnnel to mean that NHTSA approves of your product, has endorsed it in any manner, or has made commendations about it (e.g., it "can improve a driver's ability to drive safely"), that is incorrect, and we apologize for any confusion.

State laws may affect operations that you conduct in that State. If you decide to do business in a particular State, you should seek legal advice on requirements for conducting your type of business in that State, including requirements the State may have for persons modifying windshields or for vehicles with modified windshields.

I hope the enclosed information is helpful to you. Should you have any questions concerning NHTSA's legal authority, please write to me at this address or contact Dorothy Nakama of my staff at (202) 366-2992. Our FAX number is (202) 366- 3820. I am, under separate cover, returning your videotape and windshield portion.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosures

ref:104#205 d:11/13/95