Interpretation ID: 18880.nhf

Mr. Jerad Adams
Sales and Purchasing Specialist
Moriden America, Inc.
915 Western Drive
Indianapolis, IN 46241

Dear Mr. Adams:

This responds to your letter concerning the test procedures in Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials. I apologize for the delay in my response.

You seek clarification of the flammability test procedure contained in S5.3(f) of Standard No. 302, which states:

Measure the time that it takes the flame to progress to a point 1 inches from the clamped end of the specimen. If the flame end does not reach the specified end point, time its progress to the point where flaming stops.

You ask how the National Highway Traffic Safety Administration (NHTSA) would determine that flaming has stopped.

You explain that when testing a specimen to Standard No. 302, you find that the flame on the leading edge of the fabric often burns out while the flame on the trailing edge of the fabric continues to burn. You believe that NHTSA would continue timing as long as we continue to see a burning flame, regardless of whether the flame is on the leading or trailing edge of the fabric. Your understanding is correct. We would continue timing until we no longer see any flame on the fabric.

If you have any questions, please contact Nicole Fradette at this address or by phone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:302
d.2/25/99