Interpretation ID: aiam0444
Bostrom Division of UOP
Director Plastics R/D
133 West Oregon Street
Milwaukee
WI
53201;
Dear Mr. Baruth: This is in reply to your letter of August 30, 1971, to Michael Pesko of my staff, concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. Your letter asks several questions concerning the applicability of the standard to vehicle seats you manufacture. These questions are dealt with individually below.; You first ask whether Standard No. 302 applies to open air tractors earthmoving equipment, or rapid transit seating, or only to ground transportation wherein the people are enclosed by a cab or housing. As stated in paragraph S3. of the standard, it applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. These terms are defined at 49 CFR S571.3, and a copy of this section is enclosed for your information. The vehicles you mention, *i*.*e*., open air tractors, earthmoving equipment, and rapid transit vehicles are generally not vehicles of these types, but if you wish an opinion as to a particular vehicle, you must submit additional information concerning it to us. The criteria you establish, however, 'ground transportation wherein the people are enclosed by a cab or housing' is not an accurate reflection of the specific vehicle types involved, and should not be used as a guideline.; You state that you understand that 'all covering materials, foams thread, welting, etc. used in the construction of a seat is covered', and you are essentially correct, and proceed to ask several questions based on brochures of your product that you forwarded to us. These questions are answered below.; >>>1. *Adhesives*. Adhesives should be tested as part of adjacen materials whenever possible. Both the standard as issued and the notice of proposed rulemaking published May 26, 1971 (36 F.R. 9565) provide for the testing of composite materials, and adhesives joining materials that are to be tested as composites should be tested as part of the composites.; 2. *Seat composite*. Under the present standard, seat composit components that are welded together only at certain points should be treated as composites at the point of weld, and as separate materials between welds, if they are not otherwise uniformly attached to each other at those points. Under the notice of proposed rulemaking of May 26, 1971, however, this configuration would be considered as comprised only of separate materials.; 3, 4, 5. *Bearings, plastic parts and rubber parts, and shoc absorbers*. Components that comprise the seat track or suspension need not meet the standard's burn- rate requirements. Components that are included, however, that are smaller than the sample size specified in S5.2.1 may be tested using the heat-resistant wires specified in S5.1.3.; 6. *Permalator ties*. You describe 'permalator ties' as small diamete wires spaced parallel at about one inch increments, and tied together with hard twisted paper twine that are encapsulated within the foam. As both the wires and the paper twine are incorporated into the foam they must be tested if the particular foam is included within the portions of components set forth in S4.2. Furthermore, they should be tested as part of the foam.; 7. *Paint and decals*. Paint and decals on steel parts that would no be included under S4.1 need not meet the requirements of the standard. Paint and decals on steel parts that are within S4.1 should be tested as part of the steel parts.; 8. *Chassis lubricant*. Seat chassis lubricant is not within th standard's requirements.; 9. *Welting with and without paper core*. Welting with and withou paper core should be tested as part of the material to which it is attached whether it is either, as you mention, extruded vinyl or generated from the parent material. If necessary, it may be tested using the heat-resistant wires specified in S5.1.3.; 10. *Plywood*. Plywood used in seats in seat backs should be teste similarly to other materials used in the same locations.<<<; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel