Interpretation ID: nht95-2.92

TYPE: INTERPRETATION-NHTSA

DATE: May 22, 1995

FROM: Giuseppe Di Vito -- Societa Italiana Vetro S.p.A., Sede E Stabilimenti

TO: Chief Counsel, NHTSA

TITLE: Re: Request for legal interpretation, FMVSS 205.

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO GIUSEPPE DI VITO (A43; STD. 205; REDBOOK 2)

TEXT: Dear Sir,

INTRODUCTION

Siv hereby request an interpretation for the testing of a Glass-Plastic glazing item 15A, FMVSS 205. We respectfully request the NHTSA's response at the soonest possible date.

PURPOSE

We ask by this letter for your interpretation involving testing of glazing item AS 15A, Glass Plastic (Annealed Glass-Plastic for use in all position in a Vehicle except for Windshield). We request an interpretation of whether or not test no.5 (bake ANSI Z.26.1-1977) may substitute test no. 4 (boil, ANSI Z26.1-1977) for certification of compliance of that glazing.

BACKGROUND

BMW requested our company to develop a security glazing made of:

1. Door glass: Glass - Polyurethane - Polycarbonate, as per enclosed sketch no. 1. 2. Rear Quarterlite: Glass - Polyvinylbutirale, as per enclosed sketch no. 2.

Both these glass plastic parts have an internal safety spall shield to protect occupants against facial injuries coming form glass particles when the side window is broken or in case of accident. This product meets all the ECE R 43 compliance tests, whi ch include a 100 degrees C (212 degrees F) bake test. The product meets all the applicable test of FMVSS 205 except test n degrees 4 (boil test), which is not compatible with adhesion of the internal spall shield.

This type of glazing will be installed on a limited number of 1996 BMW cars to be sold in Europe and USA. BMW and SIV believe that this spall shield is an important safety innovation, whose absence would not allow introduction of these side windows into the USA.

We expect your urgent answer and thank you in advance.

Attachment Bar graphs - security glazing (omitted).