Interpretation ID: 1983-2.16

TYPE: INTERPRETATION-NHTSA

DATE: 06/13/83

FROM: AUTHOR UNAVAILABLE; Diane K. Steed; NHTSA

TO: Ford Motor Company -- Roger E. Maugh, Director, Automotive Safety Office

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Roger E. Maugh Director, Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Maugh:

This responds to your letter of June 2, 1983, regarding Ford's desire to equip 2,500 of its vehicles with Securiflex windshields to obtain field data regarding glass-plastic glazing. You state that such a test fleet would provide Ford with information regarding concerns it has about in-plant handling, vehicle assembly, mirror attachment, haze, scratching, delamination, durability, and performance in accidents.

As you are probably aware, General Motors made a similar request regarding a test fleet of Securiflex windshields last fall. We can give Ford the same assurances that were given to General Motors in response to their request. Under the limited and special circumstances of the field test described in your letter, the agency can firmly state that it would not enforce the abrasion requirement of Safety Standard No. 205 as it now stands since it does not appear to be appropriate for technology like the Securiflex windshield (Securiflex apparently cannot pass the existing abrasion requirements). That technology was developed after the standard was originally issued, and the standard did not contemplate asymmetrical glazing of this type. Equally important, the agency notes that all current information indicates that glass-plastic glazing does have a great potential for reducing lacerative injuries in accidents. The experimental use which you propose should provide valuable information regarding injury reduction and some of the remaining problems which do appear to exist with regards to this type windshield. We also note your statement that the Securiflex windshield you plan to install on the test fleet would comply with the proposed requirements for glass-plastic glazing issued by the agency March 10, 1983 (48 FR 10097).

In light of the agency's policy decision to foster the use of new safety technology by permitting the field test you propose, the agency expects your company to monitor closely the test fleet and to rectify any problems that may develop. Ford would, of course, remain responsible for meeting its obligation under the Vehicle Safety Act regarding any safety related defects. The agency also expects to be apprised of all information that Ford obtains from this field test.

Sincerely, Diane K. Steed Acting Administrator