Interpretation ID: aiam0541
Ballard Manufacturing Company
1063 E. Third Street
Pomona
CA
91766;
Dear Mr. Ballard: This is in reply to your letter of July 17, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You raise several questions in your letter which are restated below.; >>>1. 'What is the 'grace' period after the law comes into effect. .?'; Standard No. 302 was issued on December 9, 1970, and became effectiv with respect to vehicles manufactured on or after September 1, 1972.; 2. 'Are we correct in assuming that slide-in campers and trave trailers are not affected by this law. . .?'; The Standard applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. It does not apply to trailers (including 'fifth-wheel trailers') or slide-in (including 'cab over') campers.; 3. 'Does the foam in quilted plastic material need to b flame-retardant if the plastic itself (non-quilted) is already flame-proofed?'; 4. 'If the 1/4 inch foam used in quilted material is flame-proofed must a 5 inch core of foam used in a fabricated cushion be flame-proofed, also?'; The Standard provides a detailed description of the components require to meet its requirements, and of the depth of the materials in those components that are required to be tested. Generally, the answer to both of these questions is yes, material within 1/2 inch of the surface of an item is subject to the requirements.; 5. 'On recover jobs, must we replace customer's old foam wit flame-retardant foam?'; Standard No. 302 does not apply to replacement parts of aftermarke materials.; 6. 'Must the plywoods used for backs in dinettes be flame-proofed i the plastic or cloth used to upholster them is already flame-proofed?'; You should note that the Standard does not require 'flame-proofing, rather that the specimens must not burn at more than 4 inches per minute. The test specimens are determined by depth, as stated in our preceding answer, not by the nature of the material. The answer would therefore depend on whether the plywood is within 1/2 inch of the surface.<<<; Yours truly, Richard B. Dyson, Assistant Chief Counsel