Interpretation ID: nht91-1.2

DATE: 01/01/91 EST

FROM: Andy Tanner -- Glas-Weld of Jacksonville, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Subject: Labeling guidelines

ATTACHMT: Attached to letter dated 4-3-91 from Paul Jackson Rice to Andy Tanner (A37; Std. 205; VSA Sec. 108(a)(2)(A))

TEXT:

Upon the recommendation of Mr. Clark Harper, I would appreciate an official answer on a few labeling questions. Our company restores marred bus windows and renders them in like new condition in accordance with the Z 26.1 specifications.

Most of these windows were manufactured of acrylic materials produced by such companies as E I Dupont. For the sake of this example, the windows formed from Dupont product would carry the registered trade name "Lucite". As our windows are remanufactured the following questions arise:

a. Do we have to indicate the materials manufacturer or his trade name or is a generic designation which would exclude the origination information acceptable?

b. The windows, prior to restoration, conformed to the Z 26.1 specification. In our operation little material is removed from the surface and the windows retain the conformity with the original requirements as regards strength. The surface is then processed to insure good environmental properties. If the windows are basically unchanged, do we keep the original labeling or must unaltered properties be restated in our marking?

Your guidance would be greatly appreciated, as I wish to provide the proper information to both my customers and the involved Federal authorities.

Please do not hesitate to contact us, if I have failed to make any question adaquately clear.