Interpretation ID: 86-3.36

TYPE: INTERPRETATION-NHTSA

DATE: 05/29/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Greg Burns -- Quality Manager, Sierracin/TransTech

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Greg Burns Quality Manager Sierracin/TransTech 12780 San Fernando Road Sylmar, CA 91342

Thank you for your letter of March 7, 1986, to Edward Jettner of this agency. Your letter was referred to this office for reply. You asked about the effect of the certification requirements of Standard No. 205, Glazing Materials, on a product you are planning to manufacture. I hope the following discussion answers your questions.

You described your product as an aftermarket personal security speciality glazing for automotive use. The glazing would be manufactured by adding a special plastic to the interior surface of a piece of new glazing. You explained that you are having testing conducted on your product and believe that it will pass all of the requirements set for glass-plastic glazing (item AS-14) in Standard No. 205. Your specific question concerns how the glazing is to be marked in accordance with S6 of the standard.

You explained that a new item of glazing is sent to you by an original equipment glazing manufacturer, who has certified the glazing as complying with the standard and placed the necessary markings, required by S6 of the standard, on the glazing. You asked whether you should obliterate the OEM markings through sandblasting or other means and then apply your own identification or whether you should retain the OEM marking and add additional information to indicate that the glazing has been modified.

S6.1 of Standard No. 205 requires prime glazing manufacturers to mark glazing materials in accordance with section 6 of ANS Z-26. S6.1 further defines a prime glazing manufacturer as one "who fabricates, laminates, or tempers the glazing material." In general, an item of glazing has only one prime glazing manufacturer, since usually one manufacturer performs the fabrication, lamination, or tempering of the glazing material. However, in the case of your product, we would consider both the original manufacturer of the glazing and your company, which laminates a plastic material to the glazing, to be prime glazing manufacturers. Both companies are performing a fundamental manufacturing operation, such as fabricating, laminating, or tempering, necessary to produce a completed item of glazing material, as compared to a situation where a company is performing a minor finishing operation, such as polishing, to an item of glazing that is fabricated, laminated or tempered by another company.

As you pointed out in your letter, having two identifying marks on one item of glazing could lead to potential confusion as to which mark is correct. One of the purposes of the certification requirement is to assist in identifying the responsible manufacturer for the purposes of defect and noncompliance recall campaigns. Thus, in the case of your product, the agency believes that it is important that both prime glazing manufacturers be identified on the glazing since, for example, there could be a noncompliance in the original glazing sent to you or there could be a noncompliance in the glazing as modified by your company. To avoid potential confusion about what item number applies to your finished product, we agree that adding wording to your marking indicating that the original glazing has been modified from one AS item to another will help avoid confusion.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Edward Jettner TQC-86-037 Safety Glazing Standards 7 March 1986 National Highway Traffic Safety Administration Department of Transportation 400 Seventh Street Washington, D. C. 20950

Dear Mr. Jettner;

As you may be aware of, we at Sierracin/TransTech are preparing to market an aftermarket personal security specialty glazing for automotive use. The glazing would be manufactured utilizing a OEM assembly (windshield, sidelight, etc.) with the subsequent application of a special plastic to the interior surface.

We are nearing the completion of FMVSS No. 205 testing through Industrial Testing Laboratories (Berkeley, CA), and feel confident that our design will pass all tests for the AS-14 item designation of that standard. (Although we will be using the current 1983 revision to Z-26.1 instead of the obsolete 1977 revision which includes supplement .la from 1980.)

During initial conversations with Mr. Armond Cardarelli (Director, Safety Equipment Services, American Association of Motor Vehicle Administrators) in preparation for AAMVA approvals processing, the subject of assembly identification came up. As you know, OEM assemblies, when furnished in low quantities such as we would normally use, incorporate the OEM item designation (AS-1, AS-2, etc.). Mr. Cardarelli's justifiable concern was that our subsequent reidentification after our manufacturing process would cause confusion because of the conflicting item designations (AS-14 vs. AS-1/2/etc.), and he suggested that I contact you in writing to determine the proper direction in which to proceed.

As I see it, we have two options:

1) Obliterate the OEM item designation through sand-blast or other means. Thereafter we would apply our own identification.

- or -

2) Retain the OEM type designation, and add additional identification to indicate "modification" as per the following example:

(Please insert graphics)

I would appreciate your letting me know which of these two alternatives you feel would be most appropriate. If possible, we would prefer the acceptance of option two (2). If you have an alternate method that you feel would be more suitable, please contact me at the above address.

If you have any questions about this matter, please don't hesitate to call. I appreciate your participation in this, and look forward to your reply.

Sincerely yours,

Greg Burns Quality Manager