Interpretation ID: 20294.drn

Lance Tunick, Esq.
Vehicle Services Consulting, Inc.
P.O. Box 23078
Santa Fe, NM 87502

Dear Mr. Tunick:

This responds to your request for an interpretation of Standard No. 104, Windshield wiping and washing systems. Specifically, you wish to know whether Standard No. 104 has incorporated by reference the durability requirements of SAE Recommended Practice J903a, "Passenger Car Windshield Wiper Systems," May 1966. The answer is no.

In Standard No. 104, the National Highway Traffic Safety Administration has selectively incorporated by reference the following provisions of SAE Recommended Practice J903a, May 1966: The "glazing surface reference line" shown in Figure 1; the "plan view reference line" shown in Figure 2; conditions for the test procedures of the frequency and speed of the windshield wiping system (See S4.1.1.4 of Standard No. 104); wet test procedures in determining percentages of areas of the windshield that are wiped (S4.1.2 of Standard No. 104); and establishing areas A, B, and C of the windshield (See S4.1.2.1 of Standard No. 104). None of these incorporated provisions relate to any durability requirements specified in SAE Recommended Practice J903a, May 1966.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:104
d.10/26/99