ID: nht95-2.35

TYPE: INTERPRETATION-NHTSA

DATE: April 10, 1995

FROM: Terrence S. Lockman -- Legal Investigator; Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell

TO: Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 8/2/95 LETTER FROM JOHN WOMACK TO TERRENCE LOCKMAN (REDBOOK 2 VSA 102 (3))

TEXT: Dir Sir and/or Madam:

I am currently conducting an investigation involving a 1981 Versa Sweeper, manufactured by Terrain King, Sequin, Texas.

While conducting research it has become difficult to determine exactly how this vehicle would have been classified, for the purpose of applying applicable standards. I hereby request this formal inquiry.

The "Versa Sweeper" vehicle is considered to be a road/highway sweeper and/or power broom. At the time in question, the vehicle was being used in a construction zone, to sweep debris off the roadway.

I hereby submit the following inquiries:

1. For the model year, 1981, how would NHTSA had defined the Terrain King "Versa Sweeper"?

2. Under the applied NHTSA definition, for the 1981 Terrain King "Versa Sweeper", what regulations and/or standards would had applied to the manufacturing of the sweeper?

3. Did those applied regulations require the implementation of an occupant restraint system or rollover protection? If not, what is the respective date of application for implementation of those standards?

In addition to the above, I submit the following request(s) and inquiries in accordance with the Freedom of Information Act:

4. Request production of any and all correspondence and/or documentation in which the U. S. Department of Transportation, NHTSA, or an agent thereof possess regarding inquiries made by the designer and/or manufacturer, W. F. Larson Company, Amarillo, Te xas and Terrain King, regarding the manufacturing and production of the "Versa Sweeper" and all applicable standards?

A. What was the definition of use and/or application provided to the designer/manufacturer?

B. Based on the definition supplied to the designer/manufacturer, what were the Federal standards for which they were required to meet, as provided by the NHTSA?

C. At the time this product was manufactured, was this vehicle required to be equipped with an occupant restraint system and/or rollover protection?

5. Request production of any and all correspondence and/or documentation in which the U. S. Department of Transportation, NHTSA, or an agent thereof possess regarding inquiries made by a designer and/or manufacturer of a street sweeper, power broom, and /or street broom regarding the required and applicable standards?

For your review, I have enclosed copies of photographs of the "Versa Sweeper" in question. This vehicle is equipped with headlights. Ironically, however, this vehicle is not equipped with tail lights or a brake warning device.

I greatly appreciate your time and efforts towards responding to my inquiries. If you have any questions or require additional information, please contact me by calling (904) 435-7065. I look forward to receiving your response.

Enclosure VERSA SWEEPER BROCHURE (OMITTED)

ID: nht75-5.33

DATE: 08/18/75

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: John R. Hudson

TITLE: FMVSR INTERPRETATION

TEXT: This is in reference to your letter of July 28, 1975, to Corbusier Chevrolet Company of Bryan, Texas concerning that dealer's failure to provide you with an odometer mileage disclosure statement.

As you know, the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513) requires that a written disclosure of a vehicle's correct mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, the Act requires a statement to that effect to be furnished in written form to the buyer. This requirement is not limited to transactions where a dealer is the purchaser. It applies to all types of vehicle transfers, including the one in which you were involved.

In addition, the Act prohibits the alteration of the mileage indicated on an odometer. Violation of this provision and/or the disclosure statement provision may subject the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $ 1,500 or treble damages whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal court.

We have mailed a letter to Corbusier Chevrolet informing them of the relevant odometer law requirements (copy enclosed). If they fail to disclose the necessary mileage information, please let us know so that we may take additional steps to enforce their compliance with the law.

SINCERELY,

July 28, 1975

Corbusier Chevrolet Co. BRYAN, TEXAS

When I bought a 1972 Chevrolet (#1M57S2S135583) from you on September 9, 1974 I asked for a Certified Milage Statement. Your Salesman told me that this was ONLY required by the dealer and was NOT required for a retail buyer. He also told me he didn't know who the previous owner was, but that the car came from Dallas. He also told me that the car was in good condition and that he had driven it several times.

NOW I find that ANY SELLER is REQUIRED to give to ANY BUYER a written statement containing all the seller knows to be true-or-untrue, about the vehicles odometer reading and its actual milage, I WANT THIS STATEMENT NOW per "Motor Vehicle Information & Cost Savings Act". On the way home I got 10 miles to a gallon, and a big cloud of smoke came from under the hood on several occasions. The transmission has gone out now and the mechanic said he had never seen one worn out this bad with the milage indicated on the odometer.

I checked on previous registered owner and wrote to Regina Kathryn Wilson, 9827 Brock Bank, Apt 227, Dallas, Texas and the letter was returned with addressee unknown stamped on it.

John R. Hudson

CC: NHTSA; U.S. ATTORNEY; TEXAS ATTY. GENERALS OFFICE

ID: nht93-6.15

DATE: August 16, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from Ron Marion to Marvin Shaw (OCC 8838)

TEXT:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. S 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added).

This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the DRIVER'S side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

ID: nht95-1.26

TYPE: INTERPRETATION-NHTSA

DATE: January 16, 1995

FROM: Ken Liebscher -- President/Director, Electric Car Company

TO: Administrator, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 2/13/95 LETTER FROM PHILIP R. RECHT TO KEN LIEBSCHER (A43; PART 555)

TEXT: The Electric Car Company Inc. is situated at 401 Lincoln St., Box 618, Everson WA 98247. It was incorporated in the State of Nevada.

This is a petition to be exempted from six Federal motor vehicle safety standards for passenger cars that we manufacture using electric power, the MI Series Electric Car. The basis of the petition is that compliance with the standards will cause substan tial economic hardship. The standards for which the exemptions are requested are:

1. Standard # 201, Occupant protection in interior impact. 2. Standard # 203, Impact protection for the driver from the steering control system. 3. Standard # 204, Steering control rearward displacement. 4. Standard # 208, Occupant crash protection. 5. Standard # 214, Side door strength. 6. Standard # 216, Roof crush resistance.

The MI-6 (pictured) is constructed from Dupont Kevlar composite fiberglass material and according to the manufacturer, is four times the strength as conventional fiberglass and we feel confident that it will conform to all applicable Federal motor vehicl e safety standards. However, thirty-mile per hour barrier crash testing is needed to determine the actual energy absorbing characteristics. All component parts of the MI-6 are Original Equipment Manufacturer products and, as such, in compliance of Nati onal Safety Standards. The restraint systems were also purchased from OEM and are installed as per standards.

We request an exemption of two years after which we expect to certify compliance with these standards. To require immediate compliance would create substantial economic hardship. I have enclosed the last audited year end financial statement as well as the last unaudited quarterly statement. The cost for "one set" of testing for the standards on one vehicle is approximately $ 30,000, exclusive of the costs of delivering the vehicle to the test facility. An exemption would permit vehicle sales and the generation of cash permitting testing while the exemptions are in effect. The Company expects to produce six vehicles for demonstration purposes and 100 limited edition vehicles in the first year. A denial of the petition would delay the Company's pro duction while we attempt to test for conformance, but the costs of testing would require a retail price of $ 50,000 for an MI-6. We doubt that we could sell a car at this price, and that, accordingly, we would be forced out of business in the year follo wing a denial of this petition.

Granting of the exemption would be in the public interest and consistent with the National Traffic and Motor Vehicle Safety act by helping to relieve environmental problems associated with automotive transportation. The Company believes that we can make a very positive contribution to the country's clean transportation needs quickly and effectively.

(FOLLOWING ATTACHMENTS OMITTED: 1. MI-6 ELECTRIC AUTOMOBILE SPECIFICATIONS AND TECHNICAL DATA; 2. E.T.C. INDUSTRIES QUARTERLY REPORT AND FINANCIAL STATEMENTS)

ID: nht91-6.36

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Al Lipinski -- President, Mini-Max

TITLE: None

ATTACHMT: Attached to letter dated 9-18-91 from Al Lipinski to Messrs. Hall, Jackson, and Rice, NHTSA (OCC 6509)

TEXT:

This responds to your letter asking what the dynamic testing requirements are for alterers of certified vehicles. You stated that you are a small conversion company of walk in van type light trucks, that you do not alter anything forward of the B pillar of the previously certified vehicle, and that the crash protection system installed by the original manufacturer is not disturbed. You also stated that you affix an additional label stating the vehicle alterations conform to all applicable Federal motor vehicle safety standards.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. As you are aware, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.; Safety Act), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Under NHTSA's certification regulation, an alterer is a person who alters previously certified vehicles by means other than the addition, substitution, or removal of readily attachable components, or minor finishing operations, or in such a manner that the vehicle's stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale. An alterer is required to certify that every vehicle it alters continues to comply with all applicable safety standards after the alterer has performed its operations on the vehicle. See 49 CFR Part 567.7.

Alterers must have some independent basis for their certification that an altered vehicle continues to comply with all applicable safety standards. This does not, however, mean that an alterer must conduct crash testing, even with respect to standards that include dynamic test requirements. Certifications of continuing compliance for altered vehicles may be based on, among other things, engineering analyses, computer simulations, actual testing, or instructions for alteration voluntarily provided by the original vehicle manufacturer in a "body builder's guide."

Your letter suggests that you are primarily concerned about the dynamic test requirements of Standard No. 208 Occupant Crash Protection. I note that in establishing that standard's dynamic test requirements for light trucks, NHTSA made those requirements optional for walk in van type trucks. See S4.2.2 of Standard No. 208. Thus, the walk in van type

trucks you alter were not required to comply with the Standard No. 208's dynamic test requirements and may not have been designed to do so. You can find out by contacting the original vehicle manufacturer.

I hope this information is helpful.

ID: 86-2.26

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert R. Clark

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter dated October 21, 1985, inquiring about the certification responsibilities under federal law of your client, a new car dealer. You stated in your letter that your client plans to convert new automobiles into limousines. These limousines would then be sold wholesale to dealers.

The relevant federal statute is the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et seq.). Under section 103 of the Act, this agency issues Federal motor vehicle safety standards and regulations applying to motor vehicles and their equipment.

As we understand the facts stated in your letter, the automobiles will be completed by the original manufacturer who will certify that they meet all applicable Federal motor vehicle safety standards. Your client plans to alter the automobiles prior to their first purchase for purposes other than resale.

Your client's plan to convert automobiles would make him an alterer, subject to the requirements of 49 CFR Part 567.7, Certification. An alterer is a person who alters a previously certified vehicle by means other than the addition, substitution, or removal of readily attachable components or minor finishing operations, or in such a manner that the vehicle's stated weight ratings are no longer valid. If the alteration is performed before the first purchase of the vehicle for purposes other than resale, the alterer must supplement the certification label by affixing an additional label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards and containing the firm or individual name of the alterer.

An alterer is also considered a manufacturer for the purposes of notification and recall for defects or noncompliance under the Act and is subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports.

In addition, please note that your client should take care in making the conversions not to harm the vehicles' safety features. Under section 108 of the Act, a manufacturer, distributor, dealer, or motor vehicle repair business must not knowingly render inoperative, in whole or in part, any device or element of design which is installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Your client would be subject to this prohibition which applies both before and after the first purchase of a motor vehicle for purposes other than resale.

I hope this information is helpful to you.

SINCERELY,

TABBERT & CAPEHART ATTORNEYS AT LAW

October 21, 1985

Jeffrey R. Miller, Esqu. Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Miller:

On Tuesday, October 15, 1985, I telephoned your office and spoke with Mr. Steve Oeshch regarding a client of this firm who wishes to convert fully assembled automobiles into limousines. After speaking with Mr. Oeshch, he suggested that I write to your office and request a formal interpretation in regard to this matter, in view of the facts as discussed.

The client is a new car dealer in Anderson, Indiana. He desires to purchase fully assembled new automobiles from the manufacturer and subsequently convert them into limousines. The limousines will in turn be sold wholesale to dealers.

I wish to know which federal Department of Transportation statutes must be complied with and how to classify the client, i.e. dealer, manufacturer or remanufacturer.

Could you kindly at your earliest convenience render an opinion regarding this matter. Any assistance you might give me would be greatly appreciated. Thank you.

SINCERELY, Robert R. Clark

ID: nht90-3.85

TYPE: Interpretation-NHTSA

DATE: September 7, 1990

FROM: Wayne Trueman -- Plant Manager BX-100 International

TO: Barry Felrice -- Associate Administrator for Rulemaking, U.S. Department of Transportation

TITLE: None

ATTACHMT: Attached to drawings of Brake Equalizer, Quick Release Valve, and Relay Valve (graphics omitted); Also attached to letter dated 11-20-90 from P.J. Rice to W. Trueman (A36; Std. 106; Std. 121); Also attached to NHTSA Information Sheet entitled I nformation For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, dated 9-85 (text omitted)

TEXT:

I would like to thank you for your prompt response to my previous information request.

We are presently in the research and development stage of producing two (2) new products that will have the BX-100 Brake Equalizer integrally combined with a Quick Release valve and another with a Relay valve. We have completed prototype testing with bo th of these units and have proven them to be very reliable. What I would like to know from your department is if there are any design, manufacturing criteria, tests, or any other requirements that must be met in order to satisfy all local, state and fed eral regulations for items to be placed into a truck's air brake system.

I would appreciate any information that your office could provide or assistance in insuring compliance with all appropriate regulations and expectations of the regulating bodies.

Enclosed, to provide clarification on the above mentioned products, are functional view drawings on (1) BX-100 Brake Equalizer, (2) BX-100 & Quick Release Valve Assembly, (3) BX-100 & Relay Valve Assembly.

ID: nht68-3.44

DATE: 07/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 27, 1968, in which you requested clarification of the term "optically combined" as applied to motor vehicle lights.

"Optically combined" in this context means that the same lens area is used for more than one function such as tail and stop lights or stop and turn signal lights or tail, stop and turn signal lights. The normal means used to accomplish this "optically combined" lamp has been to incorporate a single dual-filament bulb with a reflector and lens.

Since the design of your Toyota Crown combination stop, tail and turn signal lamp is such that a different part of the lamp area is used for the turn signal lamp, we do not interpret it to be optically combined with the tail and stop lamp.

The concurrence of the above interpretation with yours and that of the California Highway Patrol should not be construed to be an approval of your design. The results of recent research on lighting and signaling reviewed by this Bureau indicate that signal lights should be separated 4 1/2 to 5 inches minimum (centerline to centerline separation.) Although no dimensions are specified on your drawing it appears to be approximately full scale with a separation distance of 2 1/2 inches between the stop and turn signal lamps. The steady-burning stop lamp may therefore "wash out" or significantly reduce the effectiveness on the turn signal lamp. Federal Motor Vehicle Safety Standard No. 108 does not require a minimum separation distance between signal lights; however, upon completion of our present research contracts on rear lighting and signaling, we may consider such a requirement in the future.

ID: nht95-5.55

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jerel M. Sachs -- General Manager, Automotive Glass, Import Products Glass (IPG)

TITLE: NONE

ATTACHMT: ATTACHED TO 6/26/95 LETTER FROM JEREL M, SACHS TO CLARKE HARPER; ALSO ATTACHED TO 8-4-86 LETTER FROM ERIKA JONES TO HENRY A. GORRY; ALSO ATTACHED TO 6/10/87 LETTER FROM ERIKA JONES TO DAVID C. MAROON; ALSO ATTACHED TO 6/14/90 LETTER FROM PAUL JACKSON RICE TO NORMAND LAURENDEAU

TEXT: Dear Mr. Sachs:

This responds to your June 26, 1995, letter requesting a manufacturer's code mark for automotive glazing to comply with the marking requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. You stated in your letter that you "intend to engage in the manufacture and/or contract manufacture of automotive safety glass in the United States and overseas." Your letter also stated that you were negotiating for the tooling, machinery, and the code mark of Lin's Glass Company in Taiwan.

In a June 29, 1995, phone conversation between Paul Atelsek and a member of your staff, we learned that IPG only imports and distributes; but does not actually make, glazing. He was also told that Lin's has gone out of business, and that you had switched to another supplier in Taiwan. In a July 13, 1995, phone conversation with Mr. Atelsek, you confirmed that IPG makes no glazing and that your new supplier has a code mark assigned by NHTSA, but said that you preferred to use a "fresh" number assigned to your company. You said that other companies that do not make glazing have code marks assigned to them, and named another company that you said imports "cheap" Chinese glass and applies its own manufacturer's code mark in order to disguise the origin of the glass from its buyers. In a July 13, 1995, letter in support of your request, you stated that IPG would be doing contract manufacturing with a supplier who is also supplying other customers, and that having your own number would help you monitor quality control and track your product in the marketplace. You believe that having your own number would also benefit NHTSA because the agency would have an easier time implementing a recall through IPG than through the Taiwanese supplier.

As Mr. Atelsek explained on the telephone, we cannot issue a number to your company because you are not a "prime glazing manufacturer." Standard 205, at S6.1, defines "prime glazing material manufacturer" as "one who fabricates, laminates, or tempers the glazing material." As your company does none of these things, we cannot issue a code mark to IPG. To show you that this is a matter of longstanding legal interpretation, I have enclosed some interpretation letters we have written to others asking this question and related questions.

The glass should be marked with the number we have assigned to your supplier, the prime glazing manufacturer in Taiwan. The practice you mentioned of using code marks to disguise the identity of the manufacturer is directly contrary to our policy. This code mark is supposed to help NHTSA identify the prime manufacturer of the glazing material for purposes of defect and noncompliance recall campaigns. Therefore, the code mark on a particular piece of glazing needs to refer to the company that actually, made the glazing, and code marks should never be applied to glazing made by anyone else.

I hope this information is helpful. Please feel free to contact Mr. Atelsek at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

ID: nht95-3.76

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jerel M. Sachs -- General Manager, Automotive Glass, Import Products Glass (IPG)

TITLE: NONE

ATTACHMT: ATTACHED TO 6/26/95 LETTER FROM JEREL M, SACHS TO CLARKE HARPER; ALSO ATTACHED TO 8-4-86 LETTER FROM ERIKA JONES TO HENRY A. GORRY; ALSO ATTACHED TO 6/10/87 LETTER FROM ERIKA JONES TO DAVID C. MAROON; ALSO ATTACHED TO 6/14/90 LETTER FROM PAUL J ACKSON RICE TO NORMAND LAURENDEAU

TEXT: Dear Mr. Sachs:

This responds to your June 26, 1995, letter requesting a manufacturer's code mark for automotive glazing to comply with the marking requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. You stated in your letter that y ou "intend to engage in the manufacture and/or contract manufacture of automotive safety glass in the United States and overseas." Your letter also stated that you were negotiating for the tooling, machinery, and the code mark of Lin's Glass Company in T aiwan.

In a June 29, 1995, phone conversation between Paul Atelsek and a member of your staff, we learned that IPG only imports and distributes; but does not actually make, glazing. He was also told that Lin's has gone out of business, and that you had switche d to another supplier in Taiwan. In a July 13, 1995, phone conversation with Mr. Atelsek, you confirmed that IPG makes no glazing and that your new supplier has a code mark assigned by NHTSA, but said that you preferred to use a "fresh" number assigned to your company. You said that other companies that do not make glazing have code marks assigned to them, and named another company that you said imports "cheap" Chinese glass and applies its own manufacturer's code mark in order to disguise the origin of the glass from its buyers. In a July 13, 1995, letter in support of your request, you stated that IPG would be doing contract manufacturing with a supplier who is also supplying other customers, and that having your own number would help you monitor quality control and track your product in the marketplace. You believe that having your own number would also benefit NHTSA because the agency would have an easier time implementing a recall through IPG than through the Taiwanese supplier.

As Mr. Atelsek explained on the telephone, we cannot issue a number to your company because you are not a "prime glazing manufacturer." Standard 205, at S6.1, defines "prime glazing material manufacturer" as "one who fabricates, laminates, or tempers the glazing material." As your company does none of these things, we cannot issue a code mark to IPG. To show you that this is a matter of longstanding legal interpretation, I have enclosed some interpretation letters we have written to others asking this question and related questions.

The glass should be marked with the number we have assigned to your supplier, the prime glazing manufacturer in Taiwan. The practice you mentioned of using code marks to disguise the identity of the manufacturer is directly contrary to our policy. This code mark is supposed to help NHTSA identify the prime manufacturer of the glazing material for purposes of defect and noncompliance recall campaigns. Therefore, the code mark on a particular piece of glazing needs to refer to the company that actually , made the glazing, and code marks should never be applied to glazing made by anyone else.

I hope this information is helpful. Please feel free to contact Mr. Atelsek at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.