Interpretation ID: aiam0772
Manager
Export Sales Department
Mitsubishi Motors Corporation
33-8
5-Chome
Shiba
Minato-Ku
Tokyo
Japan;
Dear Mr. Yamauchi: This is in replay to your letter of June 7, 1972, concerning whethe thin transparent polyethylene covers used to protect the inside of vehicles until delivery are subject to the requirements of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You indicate that the material does not conform to the requirements of the standard, and ask whether you may nonetheless utilize it if you place a label in the vehicle directing that the cover be removed before the car is delivered to the customer.; Whether the material must meet the requirements of the standard depend upon the likelihood that it will be retained as a protective cover by the purchaser. If it is installed in a manner that promotes its use by purchasers, we would consider it to be part of any component which it covers, and subject to the standard when used to cover those components enumerated in S4.1 of the standard. Manufacturers must therefore take appropriate steps to see that it is not so used. The use of a label that states that the material must be removed before delivery to a purchaser is one step a manufacturer might take. We believe the manufacturer should also install the material in such a way that purchasers will not wish to use it as a protective covering. If these steps are taken the NHTSA would not consider the material to be required to comply with the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel