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Interpretation ID: aiam1035

Mr. Donald W. Taylor, Engineering Liaison Representative, Volvo of America Corporation, Rockleigh, NJ, 07647; Mr. Donald W. Taylor
Engineering Liaison Representative
Volvo of America Corporation
Rockleigh
NJ
07647;

Dear Mr. Taylor: This is in reply to your letter of February 9, 1973, regarding th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You ask whether both the face and the under-surfaces of a single or composite material must meet the burn- rate requirement of Paragraph S4.3, and whether it is necessary to subject both surfaces to the flammability test in Paragraph S5.; Under Paragraph S5.2.2 of the standard, test specimens for eac component are to be tested 'so as to provide the most adverse results'. This means that the relevant test result is the most adverse one achieved in any horizontal orientation, either upward- or downward-facing. Accordingly, while every surface of a test specimen must meet the burn-rate requirement, the way you determine which positioning of the test specimen produces the most adverse results is within your own discretion.; Yours truly, Richard B. Dyson, Assistant Chief Counsel