Interpretation ID: aiam0699
RVI Washington Counsel
Recreatinal Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC
20006;
Dear Mr. Humphreys: This is in reply to your letter of April 25, 1972, concerning th application of Motor Vehicle Safety Standard No. 302 to various components of motor homes. You raise numerous questions in your letter which are restated (rephrased in some cases to facilitate our response) and answered below>; >>>1. (Page 1) 'When speaking of wheel housing and engine compartmen covers we assume this applies only to such coverings on the interior of the vehicle occupancy compartment.'; That is correct. 2. (Page 2, first paragraph) You list several components which yo assume are subject to the standard. We concur that each of these components are subject to the standard with the exception of 'gaucho and daveno' seat cushions, but only because we are not familiar with these terms.; You are also correct in your conclusion that the standard applies t the foam or other material used in seat cushions even though they may also be converted into beds.; 3. (Page 2) 'It would also appear that the standard is applicable t the mattress itself, i.e., the filling material . . . if the mattress cover is 'bonded, sewed, or mechanically attached' to the mattress itself . . .'; S4.2 of the standard lists mattress covers only, and does not apply t the filling of the mattress.; 4. (Page 2) You ask whether seat frames, constructed of plywood o similar materials, are subject to the standard. The standard is not intended to apply to seat frames, and these components need not meet its requirements.; 5. On the bottom of page 2 you refer to the language of the propose amendment to the standard (36 F.R. 9565, May 26, 1971), and ask whether mattress filling and seat frames would have to be tested under the proposal irrespective of whether they are attached to the surface material.; As stated above, neither seat frames nor mattress filling is subject t the standard and would not be required to meet the proposed requirements.; 6. (Page 3) You ask for an interpretation of the phrase 'compartmen shelves.' We consider this term to apply to open shelves, and to not include shelves which are found in cupboards or closets. However, if a shelf is a 'compartment shelf' under the standard, it must meet the requirements as it appears in the vehicle, either with or without coverings, whatever the case may be. Your statement that the standard applies 'only to such shelves if there is a shelf covering' is incorrect.; 7. (Page 3, second paragraph) We agree with your statement that th standard does not apply, with the exceptions noted, to storage cabinets or compartments. We disagree, however, with your statements regarding wall or other compartment panelling, lavatory tops, commodes or toilets, and your discussion of trim panels. We would consider walls to be side trim panels and subject to the standard. Similarly, lavatory tops may be compartment shelves under the standard, and toilets seats are included under the terms seat cushions and seat backs. Moreover, 'trim panels' include trim on walls as well as on instrument panels and doors, and they are subject to the standard.<<<; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel