ID: nht78-3.38

DATE: 11/22/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Briggs and Morgan

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your October 9, 1978, letter asking several questions concerning the modification and use of vans as school buses.

First, you ask whether your client may purchase a van that transports fewer than 10 passengers, and add passenger seating to it without complying with the school bus safety standards. The answer to your question is yes. The National Highway Traffic Safety Administration regulates the manufacture of motor vehicles. Further, the agency prohibits manufacturers, dealers, repair businesses or distributors from subsequently rendering inoperative compliance of a motor vehicle with the safety standards. However, the agency does not regulate modifications made by vehicle owners on their own vehicles.

Second, you ask whether buses manufactured after April 1, 1977, which were purchased to transport handicapped adults or other adults can subsequently be used to transport children to and from school even though the buses do not comply with the requirements. The answer to this question is the same as the answer to your first question. The agency regulates only the manufacture and initial sale of these vehicles and does not control the use of used vehicles.

Finally, you ask whether your client may purchase a 15 passenger vehicle and subsequently modify it in such a manner that it carries fewer than 10 passengers without complying with the school bus safety standards. Since the school bus safety standards apply only to vehicles carrying 10 or more passengers, a vehicle carrying fewer than 10 passengers is not required to comply with the requirements.

Although the Federal government's regulations do not prohibit the modifications that you propose in your letter, there are several other considerations of which you client should be made aware. First, although your modifications do not fall within our authority, in the case of your first and second questions the vehicles may fall within a State's definition of school bus and should comply with the school bus safety standards. Some States will not permit the registration of vehicles for school bus use if those vehicles should comply with the safety standards and do not. Therefore, you should check the appropriate State office to ensure that the vehicles you intend to modify can be used under existing State law. Second, there is a potential for increased private tort liability for accidents occurring in vehicles that should comply with safety standards but do not.

SINCERELY,

BRIGGS AND MORGAN

October 9, 1978

Roger Tilton Attorney Adviser National Highway Traffic Safety Administration

Re: Utilization of Multi-Purpose Vans in the Transportation of School Children

Dear Mr. Tilton:

As I indicated during our recent phone conversation, our office represents a Minnesota company whose operations include the transportation of handicapped school children in van-type vehicles. Prior to making final decisions regarding the purchase of additional vehicles and possible modification of others, our client has asked our assistance in seeking a clarification of certain statutory and regulatory provisions relating to the applicability of federal school bus safety standards.

As you may recall from our discussion, we have three rather specific inquiries:

1. May our client purchase van-type vehicles manufactured after April 1, 1977 which are designed to carry less than ten passengers and modify the vans so as to allow the seating of twelve or fourteen passengers without subjecting them to the federal safety standards for school buses?

2. The Company purchased a number of fifteen-passenger vans manufactured after April 1, 1977 for the purpose of transporting handicapped adults to and from their workplace. Subsequent to the purchase of these vehicles, the intended use was frustrated by the fact that the handicapped adult traffic ceased to be available. May the Company now utilize these fifteen-passenger vehicles in the transportation of school children without equipping them in accordance with the federal safety standards for school buses?

In a similar vein, the Company has considered the purchase of other fifteen-passenger vans for transporting persons to and from their jobs. If these vehicles were purchased primarily for that purpose, could they also be used for transporting school children without being equipped in conformance with the federal safety standards for school buses?

3. May the Company purchase fifteen-passenger vans and convert them to accomodate a combination of wheelchairs and regular seating not exceeding ten persons, including the driver, without application of the federal school bus safety standards?

Your initial reaction appeared to confirm our judgment that these questions may be answered in the affirmative. We would be greatly appreciative of a written response from your office which addresses the above questions in light of the applicable provisions of federal law.

I have attached a short Memorandum which was prepared in our office some time ago reviewing the applicable provisions of the Motor Vehicle Safety Act and Regulations of the National Highway Traffic Safety Administration. I have enclosed it here for your convenience.

Finally, if you find you need additional facts or a clarification of matters contained herein, please don't hesitate to call the undersigned at your convenience.

John B. Van de North, Jr.

[ENC. OMITTED]

ID: nht88-3.8

TYPE: INTERPRETATION-NHTSA

DATE: 08/19/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: PAUL SCULLY -- VICE PRESIDENT PETERSON MANUFACTURING CO.

TITLE: NONE

ATTACHMT: LETTER DATED 04/22/88 TO ERIKA Z JONES, FROM PAUL SCULLY RE INTERPRETATION OF EFFECTIVE PROJECTED LUMINOUS AREA, OCC - 1946

TEXT: Dear Mr. Scully:

This is in reply to your letter of April 22, 1988, asking for a clarification of a letter that this Office sent Wesbar Corporation on March 16, 1988, with respect to the term "effective projected luminous area."

Wesbar had asked whether it could include the "illuminated (by the turn signal bulb) reflex reflector portion of the turn signal lens" (Wesbar's language) in its calculation of the 12 square inch minimum effective projected luminous area required by S4.1 .17 of Safety Standard No. 108. We replied that it could, assuming that the light shines through the reflector. You have pointed out that although a small amount of light escapes through a reflex reflector, the reflector is designed to return light fro m an outside source, rather than to direct light from a source inside the lamp, and that heretofore agency interpretations (e.g. on October 28, 1970, and October 28, 1979) had expressly excluded reflex reflectors from areas included in the calculation of effective projected luminous area. Reflex reflectors are also excluded from the term by SAE J387 Terminology.

We appreciate your calling this matter to our attention. Previous interpretations by this Office clearly indicate that a "reflex reflector" is not to be included in the calculation of effective projected luminous area. We also note that the SAE definit ion (paragraph 2, SAE J594f,

January 1977) is incorporated by reference into Standard No. 108, stating that this item of equipment is one that provides an indication of vehicle presence by reflected light (rather than projected light). We are providing a copy of this letter to Wesbar so that it will be apprised of our reevaluation, and our conclusion that the reflex reflector portion of a lens cannot be included in the calculations of the projected luminous lens area.

I hope this clarifies the matter for you.

Sincerely,

ID: aiam5149

"Dear Mr. Pope: This responds to your February 18, 1993 letter t Walter Myers of this office. You stated in your letter and in telephone conversations with Mr. Myers that your firm obtains used wheels from salvage yards, mostly passenger car wheels, refurbishes them by sandblasting and refinishing them, then sells them to manufacturers of utility trailers. You asked how to 'bring the wheels manufactured before 1977 up to standards' (referring to Federal Motor Vehicle Safety Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars), and whether it is possible to 'stamp the wheels previous to 1977 with a regulation code to approve their usability.' 'Wheels' refers to the wheel rim and the hub to which the rim is attached. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) (Safety Act) to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles (including trailers) and new items of motor vehicle equipment (including tires and wheels). The purpose of Standard 120 is to provide safe operational performance by ensuring that vehicles to which it applies are equipped with tires of adequate size and load rating and with rims of appropriate size and type designation. The standard applies to new trailers, and to rims manufactured on or after August 1, 1977. Violations of any of the standards are punishable by civil fines of up to $1,000 per violation, with a maximum fine of up to $800,000 for a related series of violations. You ask about our requirements for the rims of the wheels you refurbish. The answer depends on whether the rim is intended to be installed on a new trailer or intended as a replacement rim for a used trailer. If the rim is intended for a new trailer, the new trailer manufacturer must certify that the vehicle complies with Standard 120. Standard 120 establishes two requirements for the vehicle. First, S5.1.1 requires that the rims on a new trailer be listed by the manufacturer of the tires mounted on the trailer as suitable for use with those tires. Second, the rims on a new trailer must meet the rim marking requirements of S5.2 of Standard 120. Since the rims you refurbish were originally passenger car rims, they will not have the required markings, regardless of date of manufacture, because Standard 120 does not apply to passenger car rims. Therefore, trailer manufacturers may not install passenger car rims on new trailers unless those rims are marked in accordance with Standard 120. If the rim is intended as a replacement rim on a used trailer, different requirements apply. The rim marking requirements of S5.2 of Standard 120 apply only to new rims manufactured on or after August 1, 1977. Refurbished wheels sold for used trailers are considered used wheels instead of new wheels for purposes of Standard 120, and are thus not subject to the rim marking requirements of the standard. As pointed out above, however, a new or refurbished rim installed on a new trailer must meet the rim selection and marking requirements of Standard 120 (S5.1.1 and S5.2). Relatedly, you ask about marking a used rim with the information required by Standard 120 for new rims. Any rim, new or used, that is installed on a new vehicle must be marked with the 'regulation code' (i.e., the 'DOT' symbol constituting the manufacturer's certification of compliance with Standard 120) and the other information required by the standard. However, a rim manufactured prior to August 1, 1977, that is sold as a replacement rim must not be marked with the DOT symbol. NHTSA has long held that manufacturers may not show the DOT certification on items of motor vehicle equipment to which no Federal motor vehicle safety standard applies. The reason for that decision is that such a certification would be false and misleading to NHTSA and to consumers who might assume that the item was subject to and met a Federal safety standard. Thus, since Standard 120 does not apply to rims manufactured prior to August 1, 1977, such rims cannot now be marked with the DOT symbol. You should also be aware of two other provisions of the Safety Act. The first provision is 108(a)(2)(A), which provides that no manufacturer, distributor, dealer, or motor vehicle repair business may knowingly render inoperative, in whole or in part, any device or element of design installed on or in a new or used motor vehicle or item of motor vehicle equipment in compliance with an applicable FMVSS. This means that a person in these categories cannot remove the label information required by Standard 120 during the refurbishing process. Second, under 151-157 of the Safety Act, manufacturers of motor vehicles and items of motor vehicle equipment (e.g., wheel rims) are responsible for safety- related defects in their products. If a manufacturer or NHTSA determines that a safety-related defect exists, the manufacturer must notify purchasers of the product and remedy the problem free of charge. (This responsibility is borne by the vehicle manufacturer in cases in which a defective wheel rim is installed on a new vehicle by or with the express authorization of that vehicle manufacturer.) A refurbished rim that had been previously damaged (e.g., cracked, bent, or pitted) might not be capable of performing safely while in service. For your further information, I am enclosing a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations and a fact sheet entitled Where to Obtain NHTSA's Safety Standards and Regulations. The pamphlet briefly summarizes each of our Federal motor vehicle safety standards and the fact sheet advises where to obtain the full text of those standards and our other regulations. You may also find helpful the attached fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment. We also note that the Occupational Safety and Health Administration (OSHA) has a regulation on the refurbishing of damaged rim components. You can contact OSHA at (202) 219-7202, ATTN: Mr. Richard Sauger, for information about that regulation. I hope this information is will be of assistance to you. Should you have any further questions, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures";

ID: 09-001535 206

ID: aiam2540

Dear Mr. Townsend: This responds to your February 9, 1977, letter in which you ask how th National Highway Traffic Safety Administration determines whether a school bus must comply with the new school bus safety standards.; On April 1, 1977, several new standards will become effective relatin to the construction of school buses: Standard No. 220, *School Bus Rollover Protection*, Standard No. 221, *School Bus Body Joint Strength*, and Standard No. 222, *School Bus Passenger Seating and Crash Protection*. Further, several old standards have been amended to provide special requirements for school buses. These amendments also become effective on April 1.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act (Pub. L. 89-563), as amended (Pub. L. 93-492), prohibits the manufacture for sale, sale, offer for sale, or introduction or delivery for introduction into interstate commerce of any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect that does not conform to the standard. This means that any school bus manufactured on or after April 1, 1977, must comply with the school bus safety standards, regardless of the date on which the bus is actually sold or introduced into interstate commerce.; For vehicles that you complete by mounting a body on a new chassis, yo are permitted to choose as the date of manufacture either the date of manufacture of the incomplete vehicle (as defined in Part 568, *Vehicles Manufactured in Two or More Stages)*, the date of final completion of the vehicle, or a date between those two dates. Only those standards in effect on the date chosen to represent the date of manufacture would be applicable to the vehicle, irrespective of the date upon which the vehicle is sold to the ultimate consumer.; I am enclosing copies of the new school bus safety standards and Par 568 for your information.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam2542

Dear Mr. Townsend: This responds to your February 9, 1977, letter in which you ask how th National Highway Traffic Safety Administration determines whether a school bus must comply with the new school bus safety standards.; On April 1, 1977, several new standards will become effective relatin to the construction of school buses: Standard No. 220, *School Bus Rollover Protection*, Standard No. 221, *School Bus Body Joint Strength*, and Standard No. 222, *School Bus Passenger Seating and Crash Protection*. Further, several old standards have been amended to provide special requirements for school buses. These amendments also become effective on April 1.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act (Pub. L. 89-563), as amended (Pub. L. 93-492), prohibits the manufacture for sale, sale, offer for sale, or introduction or delivery for introduction into interstate commerce of any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect that does not conform to the standard. This means that any school bus manufactured on or after April 1, 1977, must comply with the school bus safety standards, regardless of the date on which the bus is actually sold or introduced into interstate commerce.; For vehicles that you complete by mounting a body on a new chassis, yo are permitted to choose as the date of manufacture either the date of manufacture of the incomplete vehicle (as defined in Part 568, *Vehicles Manufactured in Two or More Stages*), the date of final completion of the vehicle, or a date between those two dates. Only those standards in effect on the date chosen to represent the date of manufacture would be applicable to the vehicle, irrespective of the date upon which the vehicle is sold to the ultimate consumer.; I am enclosing copies of the new school bus safety standards and Par 568 for your information.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: nht74-1.39

DATE: 02/25/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: Ford

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 24, 1974, asking for an interpretation as to whether a rear lamp assembly design that Ford demonstrated to NHTSA representatives conforms to the location requirements of Standard No. 108. The assembly consists of three units which, from outboard to inboard, as a rear lighting assembly, comprise the tail lamp/stop lamp, backup lamp, and turn signal lamp.

Standard No. 108 specifies that stop lamps, tail lamps, and turn signal lamps be "as far apart as practicable." The standard does not specify a minimum separation distance of lamps, a maximum permissible location inboard, or location of one system relative to another. The determination of practicability in lamp spacing is to be made by the vehicle manufacturer, and the agency has generally afforded manufacturers some latitude in this interpretation.

Therefore, the configuration you have described and demonstrated would not violate Standard No. 108. It should be noted, however, that it would be in conflict with the requirements for rear turn signals and stop lamps as proposed in Docket 69-19, Notice 3.

Sincerely,

ATTACH.

January 24, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Dr. Gregory:

On January 14 Ford demonstrated a rear lamp design that it plans to use on one of its 1975 models. The purpose of the demonstration was to display the design and make sure there were no misunderstandings as to the lamp's conformance with the location requirements of Motor Vehicle Safety Standard No. 108. Ford pointed out that the various functions of the lamp were "as far apart as practicable" for the rear end design of the vehicle and for the separation of signal functions by space and color in which both the NHTSA and Ford are interested.

For the record the lamp assembly may be described as follows: Red White Amber Left side shown (Approximately to scale)

* The outboard pod has a red lens and wraps around the quarter panel, thus serving as a rear side market, taillamp and stop lamp and as side and rear reflex reflectors.

* The center pod has a white lens and serves as the backup lamp.

* The inboard pod has an amber lens and serves as the turn signal lamp.

While it is our impression that NHTSA technical personnel who examined this lamp design agreed that it fully meets the location requirements of Standard No. 108, we should appreciate formal confirmation that the Administration concurs in our interpretation.

Respectfully submitted,

J. C. Eckhold -- Director, Automotive Safety Office, FORD MOTOR COMPANY

ID: 8083

Air Mail

Mr. M.K. Chaudhari Director ARAI The Automotive Research Association of India Post Box No. 832 Survey No. 102, Vetal Hill Off Paud Road, Lothrud Pune-411 004 INDIA

Dear Mr. Chaudhari:

This responds to your follow-up letter of November 16, 1992, subsequent to our response, dated August 12, 1992, to your earlier letter. I am pleased that the information given you in our previous letter is proving helpful in your work. In your current letter you request information regarding DOT certification of automotive components in general, and "brake hose ends" in particular.

I would like to clarify the relevant points made in our last letter to clear up any misunderstandings. Neither the Department of Transportation (DOT), nor the National Highway Traffic Safety Administration (NHTSA, a part of DOT) conduct any certification testing. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), a copy of which I have enclosed, the manufacturer is responsible for certifying that its components or vehicles are in compliance with NHTSA's safety standards.

Manufacturers must have some basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations.

NHTSA tests vehicles and equipment sold to consumers for compliance with the FMVSS's and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties.

With respect to your specific question about "brake hose ends," Standard No. 106, "Brake Hoses," applies to new motor vehicles and to "brake hoses" (which include plastic tubing), brake hose end fittings, and brake hose assemblies. A copy of the standard is enclosed. The standard specifies labeling and performance requirements for these products to reduce the likelihood of brake system failure from ruptures in the brake hose or brake hose assembly. New brake hoses, end fittings, and assemblies must meet these requirements to be sold in or imported into this country. If the items do not comply, the manufacturer is subject to the civil penalties and the recall responsibilities mentioned above.

I have enclosed a copy of the test procedure manual used by the agency in its tests to verify compliance of the brake hoses. However, please see the Note on page 1 of the procedure manual regarding a manufacturer's certification testing.

NHTSA does not authorize testing agencies to perform certification procedures. Therefore, we cannot provide a list of the agencies in India or elsewhere that are capable of certifying motor vehicles or motor vehicle equipment.

I hope this information clarifies NHTSA's role in the certification process. If you have any further questions about NHTSA's safety standards, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992. Our fax number is (202) 366-3820.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:106 d:2/9/93

ID: nht93-1.30

DATE: 02/09/93

FROM: JOHN WOMACK -- ACTING CHIEF COUNSEL, NHTSA

TO: M.K. CHAUDHARI -- DIRECTOR ARAI/ THE AUTOMOTIVE RESEARCH ASSOCIATION OF INDIA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM M. K. CHAUDHARI TO PAUL JACKSON RICE (OCC 8083)

TEXT: This responds to your follow-up letter of November 16, 1992, subsequent to our response, dated August 12, 1992, to your earlier letter. I am pleased that the information given you in our previous letter is proving helpful in your work. In your current letter you request information regarding DOT certification of automotive components in general, and "brake hose ends" in particular.

I would like to clarify the relevant points made in our last letter to clear up any misunderstandings. Neither the Department of Transportation (DOT), nor the National Highway Traffic Safety Administration (NHTSA, a part of DOT) conduct any certification testing. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), a copy of which I have enclosed, the manufacturer is responsible for certifying that its components or vehicles are in compliance with NHTSA's safety standards.

Manufacturers must have some basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations.

NHTSA test vehicles and equipment sold to consumers for compliance with the FMVSS's and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties.

With respect to your specific question about "brake hose ends," Standard No. 106, "Brake Hoses," applies to new motor vehicles and to "brake hoses" (which include plastic tubing), brake hose end fittings, and brake hose assemblies. A copy of the standard is enclosed. The standard specifies labeling and performance requirements for these products to reduce the likelihood of brake system failure from ruptures in the brake hose or brake hose assembly. New brake hoses, end fittings, and assemblies must meet these requirements to be sold in or imported into this country. If the items do not comply, the manufacturer is subject to the civil penalties and the recall responsibilities mentioned above.

I have enclosed a copy of the test procedure manual used by the agency in its tests to verify compliance of the brake hoses. However, please see the Note on page 1 of the procedure manual regarding a manufacturer's certification testing.

NHTSA does not authorize testing agencies to perform certification procedures. Therefore, we cannot provide a list of the agencies in India or elsewhere that are capable of certifying motor vehicles or motor vehicle equipment.

I hope this information clarifies NHTSA's role in the certification process. If you have any further questions about NHTSA's safety standards, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992. Our fax number is (202) 366-3820.

ID: 1982-3.6

TYPE: INTERPRETATION-NHTSA

DATE: 09/27/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: New York City Transit Authority

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Donald J. Cameron Director - Technical Support New York City Transit Authority 25 Jamaica Avenue Brooklyn, New York 11207

Dear Mr. Cameron:

This responds to your recent letter asking whether the driver's side window and the front entrance door window of a bus may be equipped with plastic glazing. You desire to use plastics because of the high operating cost of replacing broken glass windows.

The answer to your question is no. Safety Standard No. 205, Glazing Materials, was amended in 1977 to permit the use of rigid plastic glazing in all doors and windows of buses, except windshields or windows to the immediate right or left of the driver(42 FR 61465). The reason for this exception is that windows to the immediate right and left of the driver are necessary for driving visibility and typical plastic material used alone is not sufficiently resistant to abrasion. Plastic glazing would not be allowed in a bus entrance door since this would constitute a "window to the immediate right" of the driver. Plastic glazing would be allowed in the rear emergency door, however, if that door was not necessary for driving visibility.

You also ask whether material other than safety glass may be used in either of these locations. I am not sure that I correctly understand your question. If by "other materials" you mean, for example, sheet metal, the answer to your question would be yes. There are no Federal requirements specifying that a vehicle have windows in a certain location. Thus, theoretically, there would be nothing to preclude the installation of a solid metal entrance door in a bus. (Obviously, no manufacturer would likely do this because it would compromise driver vision.) If, however, there is a window and it is equipped with traditional glazing materials, the glazing must be in compliance with the performance and location requirements of Standard No. 205. If I have misunderstood your last question, please contact Hugh Oates of my staff and he will clarify the requirements for you (202-426-2992).

Sincerely,

Original Signed By Frank Berndt Chief Counsel

National Traffic and Highway Safety Administration Department of Transportation Office of the Chief Council 400 Seventh Street South West Washington, D.C. 20590

Greetings:

Reviewed of the Automotive Safety Glazing Materials Standard #205 and the 2-25 document, has caused the Technical Support Department some confusion in its interpretation. Your assistance in clarifying the following points would be greatly appreciated.

Replacement of glass on New York Transit Coaches is a major item in our operating costs. My questions are in regard to the driver's side window (immediate left of driver), and the front entrance door glass. Can either of the above-mentioned items be replaced with plexiglass (plastic)? Can material other than safety glass be used in either of these locations?

Thank you for your attention. We look forward to your reply.

Sincerely,

Donald J. Cameron Director - Technical Support