Interpretation ID: aiam2423
Global Market Planning Manager
Solar Control Products
3 M Company
3 M Center
Saint Paul
MN 55101;
Dear Mr. McNiff: This is in response to your September 22, 1976, letter regarding th use of 'Solar Control Reflective Films' in motor vehicles. You asked several questions concerning the applicability of Federal requirements to the manufacture and sale of your 'Scotchtint' protective film.; I am enclosing a copy of a letter to Mr. Mark T. Lerche from thi agency that discussed the applicability of Federal requirements to his company's 'Madico' solar protective film. The discussion in that letter is equally applicable to 'Scotchtint' protective film and should answer your questions. The main point to be noted is that these protective films that are attached to glass are not 'glazing' themselves and, therefore, the requirements of Federal Safety Standard No. 205 are not applicable to the manufacture of the film. It is the responsibility of the manufacturer, dealer, or vehicle repair business that applies the film to ensure that glazing remains in compliance with the standard. Of course, if your company applies the film to any glazing you would fall in this same category.; It is laudable that your company is interested in ensuring that it film is not used in a manner that would be detrimental to the safety of the motoring public. Although it is not your responsibility to do so, a safety warning to your consumers that 'Scotchtint' should not be placed on vehicle glazing in 'areas requisite for driving visibility,' would be helpful.; We appreciate your interest in motor vehicle safety. Sincerely, Frank Berndt, Acting Chief Counsel