Peg Stroka
Manager of
Industry Standards
717-558-0939
pegs@glass.org
Suzanne Hurst
ANSI, Executive
Assistant to General Council
6th floor
Anne Caldas
ANSI, Director of
Procedures & Standards Administration
Dear Ms Hurst and Ms. Caldas,
As the standards developer for the Repair of Laminated Automotive Glass
Standard (ANSI/NGA R1.1-2007), the National Glass Association (NGA) must object
to section 7.3 (Modified Glazing Markings) of the proposed SAE Z26.1
standard.
“7.3 Modified Glazing Markings: All modifications to the glazing materials made by someone other than the original glazing manufacturer shall be permanently marked on the glazing.”
This proposed Section conflicts with decisions already addressed during
the development of ANSI / NGA R1.1-2007, Repair of Laminated Automotive Glass
Standard (ROLAGS).
NGA’s objections are:
1.) NGA requested representation on the SAE Z26.1 committee. We asked
to receive minutes of previous meetings and a list of Z26.1 members. NGA was
rebuffed by Z26.1 Chairman, John Turnbull and staff person, Micheline Brussow.
In the summer of 2007, NGA’s Peg Stroka was told she could attend SAE
Z26.1 meetings as a guest but her requests to serve as a member were
discouraged by the SAE rationalization that Z26.1 dealt “only” with issues
affecting OEM manufacturers and not the “aftermarket” addressed by the Repair
of ROLAGS.
In fact, “all modifications” directly applies to aftermarket issues
that are already covered by ANSI/ NGA R1.1-2007 (ROLAGS).
Peg Stroka and I met with John Turnbull in early September of 2007 and
were again told SAE Z26.1 would not deal with aftermarket issues covered
by ROLAGS and that work on a revised Z26.1 had not even begun. A short time
later, that nonexistent revision was published.
NGA was denied the participation which ANSI
guidelines on “openness” require.
2.) The SAE Z26.1 Committee was
aware of ROLAGS before the draft of a revised Z26.1 was published. We know that
to be true because a member of the Z26.1 Committee submitted comments to the
ROLAGS Standard Developing Committee (SDC).
The NGA SDC is comprised of auto glass industry professionals who
represent every part of the auto glass industry from large glass manufacturers
to single location retail auto glass companies that specialize in repair or
replacement of damaged auto glass in the aftermarket. These professionals
discussed and rejected the additional permanent markings to windshields as
impractical, unnecessary and, therefore, unneeded
Permanently marking the glass suggests the glass is to be etched.
Etching disturbs the surface of the glass and succeeds only in creating an area
of questionable integrity. Since multiple windshield repairs on a windshield
are common, it is difficult to imagine how each repair can be linked to the
company that performed that specific repair without obscuring driver visibility.
NGA believes Section 7.3 of Z26.1 is unreasonable, unfair to the public
interest and totally unsuitable for national use. Z26.1 has done nothing to demonstrate a need
or purpose for marking the glass in its 7.3 recommendations. There can be only one reason to require
permanent markings identifying each company who repaired one or more damages on
a windshield and that is to discourage windshield repair and force consumers to
choose the more costly option of replacing their damaged windshield.
3.) ANSI Essential Requirements stipulate the BSR shall not approve
standards that duplicate existing American National Standards unless there is a
compelling need. Section 7.3 (above) goes beyond duplicating ROLAGS; Section
7.3 contradicts and conflicts with ROLAGS without stipulating a need – much
less a compelling need.
As originally written in 1938, and as recently as the last version
written in 1996, SAE Z26.1 only addressed original equipment glass (before it
was sold to the end user). Their new proposed version addresses aftermarket
glass (glass after it has been installed and sold to the end user).
After 70 years, Z26.1 suddenly includes areas it previously ignored;
provides no justification for its recommendations; ignores the NGA Secretariat’s
attempts to participate in the “open” process; and, makes no attempt to
“harmonize” with ROLAGS.
Permanent marking of windshields is not in the public interest and
could, potentially, deny consumers their only option to a less costly
methodology to manage damaged windshields.
Therefore, NGA asks the ANSI BSR to deny
approval to the revised SAE Z26.1.
Sincerely,
Margaret J. Stroka
Manager of Industry
Standards
& Auto Glass
Cc: John Turnbull
SAE ANSI Z26 Committee
755 W. Big Beaver,
Jack Pokrzywa
SAE Automotive Headquarters Operations Manager
755 W. Big Beaver,
Micheline Brussow
SAE Vehicle Systems Group, Standards Specialist
755 W. Big Beaver,