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Interpretation ID: aiam3953

Mr. Ernest Astle, Purchasing Agent, Alco Manufacturing Company, P.O. Box 724, Logan, UT 84321; Mr. Ernest Astle
Purchasing Agent
Alco Manufacturing Company
P.O. Box 724
Logan
UT 84321;

Dear Mr. Astle: This responds to your letter to Steve Kratzke of my staff asking for a interpretation of the requirements of Standard No. 302, *Flammability of interior materials* (49 CFR 571.302). Specifically, you asked if the requirements of that standard apply to aftermarket seat covers. While the standard applies only to new motor vehicles, its requirements do indirectly affect some aftermarket seat covers. As explained in greater detail in the attached letter to Mr. Cederbaum regarding the same issue, rendering inoperative equipment or elements of design installed in a vehicle pursuant to the Federal motor vehicle safety standards is prohibited if done by certain commercial enterprises, but is permitted if done by the vehicle owner. Thus, if a seat cover in a complying vehicle were replaced with a noncomplying seat cover by one of those enterprises, that act would violate the above prohibition. The same act, if done by the owner, would not be a violation.; Should you need further information or have any further questions i this area, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Jeffrey R. Miller, Chief Counsel