Interpretation ID: aiam1810
Vice President
Sales
YKK ZIPPER (U.S.A.)
Inc.
Illinois Division
2165 Shermer Road
Northbrook
IL
60062;
Dear Mr. O'Reilly: This is in response to your letter of February 13, 1975, in which yo ask whether zippers fall under the purview of Federal Motor Vehicle Safety Standard No. 302.; S4.1 of the standard states that the following components of passenge cars, multipurpose passenger vehicles, trucks, and buses must meet its requirements:; >>>Seat cushions, seat backs, seat belts, headlining, convertible tops arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.<<<; To the extent that a zipper is a part of any of these components, i would fall within the ambit of the standard. While recreational vehicles are not currently covered by Standard No. 302, the National Highway Traffic Safety Administration issued on November 15, 1974, a Notice of Proposed Rulemaking to extend the coverage of the standard to include recreational vehicles (copy enclosed).; You should also be aware that other rulemaking relevant to the coverag of the standard is underway and will soon be published in the *Federal Register*. For this reason, we recommend you subscribe to either the Government Printing Office Safety Standard subscription service or an equivalent commercial service as detailed in the enclosure.; Sincerely, James C. Schultz, Chief Counsel