Interpretation ID: aiam0860
Engineering Representative
Nissan Motor Co.
Ltd.
560 Sylvan Avenue
Englewood Cliffs
NJ
07632;
Dear Mr. Nishibori: This is in reply to your letters of August 8, and August 28, 1972 requesting interpretation of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; In your August 8th letter, as we understand your first question, yo ask whether the adhesive, sound-proofing material used on the floor panels of your cars should be tested together with the few insulating fibers which become embedded in this material when the insulation which covers the sound- proofing material is removed. The Standard provides a list of the interior components which must meet its requirements and the manner in which those components are to be tested. Since the sound-proofing material you have described would not be considered a floor covering and it is not otherwise included in S4.1 of the Standard, it is not subject to the requirements.; You ask further whether the 'seal screen' you glue peripherally on th inner, door panels to prevent water from penetrating the interior of the door must meet the requirements of the Standard. The 'seal screen', as you describe it, does not appear to be part of the panel and, accordingly, it would not be subject to the Standard.; In your August 28th letter, you ask whether the procedure you have fo testing the 'jute' insulating material used under the floor carpet of your cars conforms to the requirements of Standard No. 302. You state that this procedure includes removing the insulation and testing its top surface, which you designate as 'surface B', rather than testing its bottom surface, which you designate as 'surface A'. We are not sure what you mean by testing a 'surface', the Standard refers to a test for the entire specimen. You may be concerned with whether the specimen is oriented upward or downward. Under the Standard, the test specimen for each component is to be tested 'so as to provide the most adverse results'. Accordingly, the relevant test result is the most adverse one achieved in any horizontal orientation, either upward- or downward-facing. The fact that you remove the insulating material so as not to raise the nap on its bottom surface is consistent with existing test procedures.; Yours truly, Richard B. Dyson, Assistant Chief Counsel