Interpretation ID: aiam0611
Technical Development
Liaison Engineer
Volkswagen of America
Inc.
Englewood Cliffs
NJ
07632;
Dear Mr. Krueger: This is in reply to your letter of December 6, 1971, in which you as several questions regarding the test procedures of Standard No. 302, 'Flammability of Interior Materials,' and list certain components asking whether they are subject to the standard. While we indicated to you in our letter of February 17, 1972, that we are considering amendments to the standard which affect the questions you raise, we are responding, because of the limited time remaining before the standard becomes effective, to your questions based on the standard as presently written, indicating where appropriate, those areas where modifications may be made.; The three questions you raise regarding the test procedures of th standard are restated in part below, followed by our response.; >>>1. How is a part whose largest dimension is less than one inch an which is subject to the requirements of S4.1 to be tested under S5? You state that many small parts of Volkswagens would fall through the wire grid if required to be tested.; If a component fits the criteria of S4.1, it is required to meet th standard's requirements regardless of its size. In testing, however, manufacturers are not required to follow the procedures set forth in the standard, but may modify those procedures as long as results obtained can be correlated sufficiently that the manufacturer can show he exercised due care in attempting to meet the requirements. In the case of components that are too small to be supported by the wire grids, we believe manufacturers would be free to space the wire grids so that, at the very least, the component can be supported, and still avail themselves of a due care defense. One other alternative, although not as easily correlated to the standard, would be to test samples of the material of which the component is manufactured in sizes large enough to be supported by the test device as described in the standard.; 1(a). If the specimen held in the frame offers less than 1.5 inches o material from its open end to its clamped end, does it have to be tested under MVSS 302?; The answer to this question is similar to the one above. There is n exemption for small components in the standard. However, minor modifications to the test procedure may be made without jeopardizing the ability of a manufacturer to demonstrate, should the need arise, that he has exercised due care. In this case, we believe that a manufacturer could begin timing before the flame had traveled 1.5 inches, or again, could test larger samples of the material of which the component is made.; 1.(b). If a small specimen held in the frame offers less than 2 inche of material for progression of the flame after timing has begun, and if the material stops burning before it has burned for 60 seconds from the start of timing, does it meet the requirements of S4.3?; The provisions of S4.3 that you refer to are intended to reflect th performance of samples described in the test procedures of S5. These requirements are intended to provide an exemption for self-extinguishing materials, and not to exempt small samples that are consumed by fire before two minutes elapse. The standard establishes burn-rate requirements, and manufacturers should keep this in mind in determining whether particular components comply. If your component is such that it is consumed by fire because of its size before the two-minute period, then we would expect modifications to the procedure, of a nature described above, to be made in order that a determination of the burn rate of the material is obtained.; 2. 'We do not understand the applicability requirements of S4.1 specifically the latter part of the paragraph which states, ' . . ., 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.'' You then list certain components and ask whether they fall within the quoted language.; This provision is presently under review by NHTSA, and may be modifie in the amendment to be published in the near future. Any such change may also affect the problems you appear to have in testing very small components, as indicated by your previous questions. However, as presently written, the phrase refers to those components which are in fact designed to be energy absorbing. This determination must be made by the manufacturer, based upon the design of his vehicles. It does not appear to us that any of the components you list would necessarily fall within the quoted language.; The list you provide includes numerous gaskets, or gasket-typ components such as (a) windshield gasket, (b) side door insulating rubber, (c) door gaskets, (h) rubber boots at base of gear shift and hand brake levers, (l) gaskets for sliding sun roof, and (m) gasket between steering column and firewall. If these items are not within the above-quoted language of S4.1, we would not consider them to be covered by any other language of that paragraph.; With reference to the open truck compartments in Type 2, Type 3, an Type 411 vehicles (your paragraph (d)), we consider areas in passenger vehicles where occupants can ride, such as the rear of station wagons, to be within the occupant compartment, and the components listed in S4.1 that appear in these areas must meet the requirements.; With reference to paragraph (e), we would consider the battery cover if it is part of the floor, to be a floor covering within S4.1 However, we do not consider electric cables (f) to be within any of the enumerated items of S4.1. In addition, the brake fluid reservoir (g) would only be included if it is within the 'any other interior materials . . .' language of S4.1.<<<; Sincerely, Lawrence R. Schneider, Chief Counsel