November 9, 2005
National Highway Traffic Safety Administration
400 Seventh Street, SW
Washington, DC 20590
Dear Ms. Glassman:
On October 16, 2005, the first ever conference of the Automotive Glass Replacement Safety Standards (AGRSS) Council convened in Las Vegas, Nevada to bring together committee members and industry representatives to learn more about the safe replacement of automotive glass.
The AGRSS Council, a 501(c)(3) nonprofit organization, was formed by stakeholders within the automotive glass replacement industry to develop a standard for the proper procedures, product performance and education relating to the safe installation of automotive replacement glass. The AGRSS standard (ANSI/AGRSS 002-2002) is the first automotive glass replacement standard.
The safety implications of this standard–and proper automotive glass replacement in general—can hardly be understated. As a result of NHTSA’s inadequate roof crush standard, FMVSS 216, manufacturers have built–and continue to build–vehicles that meet the standard by relying on the windshield to provide at least 30 percent of roof strength.
Current FMVSS 216 requirements only consider the deformation of the roof caused by flat platen loading on one side of the vehicle, in which the platen is oriented at a shallow angle and applied to the center of the roof near the B-pillar. In this scenario the load is spread over the area from the A-pillar and windshield back to the B-pillar. But this test does not mimic real life.
In a rollover crash the windshield is typically fractured during the first half roll as the vehicle hits the ground close to the A-pillar along the leading roof edge. As the vehicle completes a roll, side pillars and roof panels now more easily deform into the occupant compartment and fracture side windows, causing occupant injury and creating portals for occupant ejection.
Rollover is a significant cause of motor vehicle trauma and accounts for one-third of occupant fatalities in motor vehicle crashes.
Even the most strongly bonded windshield will fracture if the roof deforms in a rollover crash. Therefore NHTSA must adopt two sided testing in its pending rulemaking to upgrade the outdated and inadequate roof crush standard. Better still, NHTSA should go with the optional dynamic dolly rollover test of FMVSS 208 as was upheld by the 6th Circuit Court of Appeals in Chrysler Corp. v. DOT, 472 F2d 659 (1972), over 30 years ago. The model for windshield retention should be the Volvo XC90, with a roof strength of 3.5 to 1, which can sustain three rollovers without deforming the roof or fracturing the windshield.
Notwithstanding the pressing need for a better roof crush standard, motorists should be assured that the roof strength of a vehicle on the road today is not unnecessarily compromised as the result of a windshield replacement. Inappropriate adhesive applications, shortened drive-away times, and improper glass handling techniques are just a few of the dangerous shortcuts plaguing the auto glass replacement industry and resulting in an unknown number of weak windshield installations which will not even protect occupants from the first impact in the first half roll.
Furthermore, an incorrectly mounted windshield may not even be strong enough to withstand the impact of a passenger airbag, which is designed to fire into the windshield for proper positioning. If improperly installed, a replacement windshield can literally be blown out of its mounting by passenger airbag detonation.
The AGRSS standard was written with these concerns and motorist’s safety in mind. Windshields replaced in accordance with the AGRSS standard will provide a level of safety equivalent to the requirements set forth in FMVSS 212: windshield mounting.
Consumers should expect no less from their windshield repair shop, and yet the fraction of correctly installed replacement windshields in the nationwide market of up to16 million annual jobs is unknown. Unsafe windshield replacements have been documented by ABC’s 20/20 television news program (February 25, 2000) and have been blamed for injuries and deaths in several lawsuits. Accurate estimates of injuries due to deficient windshield installation are unavailable from NHTSA due to the highly specific nature of this uncollected data. Standard police reports do not account for windshield mounting as a cause of injury.
Certainly, though, the problem is more widespread than a few shoddy replacements or fly-by-night shops, considering that the AGRSS standard is the culmination of a 7 year effort by a dedicated cadre of proprietors who wish to distinguish themselves on the basis of quality, safety, and adherence to best practices.
As of today, about 280 of the thousands of glass replacement shops have registered with the AGRSS Council. These inaugural members of the AGRSS Council should be commended and the multiplication of their ranks encouraged. Diffusion of the AGRSS standard benefits the legitimate glass replacement industry and consumers, who are all too often unaware of the details and implications of windshield replacements.
In this endeavor NHTSA can help.
A consumer advisory, detailing the importance of windshield integrity, the relationship to roof strength and rollover crashes, proper replacement procedures–and the AGRSS standard, would call attention to a key component of automotive safety and importantly serve a more informed motoring public.
More importantly, NHTSA must issue a revised roof crush standard that obviates the windshield’s role as a structural component of the vehicle roof.
I urge NHTSA to issue such an advisory and revised roof crush standard.