Mr. K. J. Sato
President & CEO
Tekno-Info Corporation
500 Trotwood Place
Louisville, KY 40245-4071

Re: Request for Clarification of S5.1.2(b)

Dear Mr. Sato:

This responds to your letter of December 4, 1995, to Kenneth Hardie of this agency, asking for interpretation of paragraph S5.1.2(b) of Motor Vehicle Safety Standard No. 108. Your request covers both the present version and the amended one which becomes effective March 1, 1996.

Paragraph S5.1.2 (1996) requires plastic materials used for optical parts such as lenses and reflectors to conform to SAE Recommended Practice J576 JUL91. However, exceptions to this general requirement are set out in subparagraphs (a) through (g). You ask whether plastic materials which conform to J576 JUL91 except for one of the appearance requirements (e.g. delamination) "are considered in compliance with S5.1.2(b) and can be used for lenses (other than those incorporating reflex reflectors)."

S5.1.2(b) states that "[a]fter the outdoor exposure test, the haze and loss of surface luster of plastic materials (other than those incorporating reflex reflectors) used for outer lenses shall not be greater than 30 percent haze as measured by ASTM D 1003-92, Haze and Luminous Transmittance of Transparent Plastic;." The exception to paragraph S5.1.2 set out in S5.1.2(b) is the substitution of the 1992 version of ASTM D 1003 for the 1977 version specified in J576 JUL91. This exception does not affect the basic requirement of paragraph S5.1.2 that plastic materials meet all the appearance requirements of J576 JUL91 including retention of lamination.

You have asked whether this clarification also relates to paragraph S5.1.2(b) as in effect until March 1, 1996. The answer is yes. Paragraph S5.1.2 of the current version is identical to the later version except that it refers to the May 1970 version of SAE J576, while the reference in S5.1.2(b) is to the 1961 version of ASTM D 1003. SAE J576c May 1970 also requires that no delamination appear after the outdoor exposure test.

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:2/1/96