Interpretation ID: aiam0441
Project Manager
Designing Division
Toyo Kogyo Co.
Ltd.
6047 Fuchu-Machi
Aki-Gun
Hiroshima
Japan;
Dear Mr. Mitoya: This is in response to your letter concerning 'Parts Subject to MVS No. 302,' your reference No. P-71-10, dated June 21, 1971. In paragraph A of your letter you list several vehicle components and ask whether, because the size of the component is small when compared to the specified sample size of S5.2, the component must still meet the requirements of the standard. If so, you ask which components, based upon pictures of the vehicle that you enclosed, are subject to the standard.; The answer to your question is yes. Whether a particular component mus meet the requirements of the standard does not depend upon its size, but upon whether it is included within the language of S4.1. If a particular component is smaller than the sample size specified in S5.2.1, it may be tested using the heat resistant wires described in S5.1.3.; With regard to whether the components you list are subject to th standard, in our answer we have combined those you listed in question A as well as in question B. Our answers are based solely upon the pictures you submitted and not an actual vehicle, and we cannot therefore be specific in all instances. While none of the components you list is specifically referred to in S4.1, some of the components appear to closely resemble or to be merely different descriptions of items that are enumerated. If so, they are subject to the standard. These are the parcel shelf and scarf plate. Seaming welt and seaming rubber should be considered as part of the component to which it is attached and for which it provides a seam.; Whether the other items you list are subject to the standard depend upon whether they are 'other interior materials . . . designed to absorb energy on contact by occupants in the event of a crash.' The components that you list that may fall within this category are the head restraint adjuster knob, radio, lighter, choke and other knobs, combination switch knob, steering wheel, transmission control lever knob, door latch release cover, window control knob, seat slide knob, reclining knuckle cover, room lamp, interior rear view mirror, meter case, glove compartment door, decoration plate of radio and clock, steering column cover, console, venitilation (sic) (ducts), transmission control lever boot, heater, steering wheel hub, and air conditioner. Items that we can determine would not be covered under this language would be the pedal pads and the wiring beneath the instrument panel.; If you have additional questions, please write to us. Sincerely, Lawrence R. Schneider, Acting Chief Counsel