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Interpretation ID: aiam0734

Mr. Erwin Strasmich, Vice-President, Ross Matthews Corporation, East Warren Street, Fall River, MA, 02722; Mr. Erwin Strasmich
Vice-President
Ross Matthews Corporation
East Warren Street
Fall River
MA
02722;

Dear Mr. Strasmich: This is in reply to your letter of May 19, asking whether elasti fabric you manufacture must meet the requirements of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials' (49 CFR 571.302). You state that the fabric is under one inch wide, is tunneled and covered in automobile map pockets and similar accessories, and is not exposed in the finished product.; Paragraph S4.1 of Standard No. 302 (copy enclosed) lists the component of motor vehicles that must meet the burn rate requirements. Whether your elastic is required to meet these requirements depends upon whether it is incorporated into any of these enumerated components. We would consider, for example, a map pocket attached to the inside of a vehicle door to be part of a door 'trim panel,' and consequently subject to the standard. If your material is used in any component listed in S4.1, it would be required to meet the standard's requirements when tested as part of the component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel