Interpretation ID: aiam2157
Consumer Product Safety Commission
Washington
DC
20207;
Dear Ms. Freeston: This is in response to your letter of February 10, 1976, in which yo request our opinion concerning the applicability of Federal Motor Vehicle Safety Standard No. 302 to mattresses.; You are correct in saying that the amendment to S4.2 of Standard No 302, promulgated on March 31, 1975 (40 FR 14318), extends the coverage of the standard to '(a)ny portion of a single or composite material which is within 1/2 inch of the occupant compartment air space...' S4.1 of the standard provides, however, that '(t)he portions described in S.4.2 of the following components shall meet the requirements (of the standard)....' S4.1 then lists the components to which the standard applies. While mattress covers are included in the listing, mattresses are not. Consequently, Standard No. 302 does not apply to mattresses as such.; You should be aware that a notice of proposed rulemaking was als issued on March 31, 1975 (40 FR 14340) proposing that any material within 1/2 inch of the occupant compartment air space meet the requirements of the standard. Should this proposal be adopted, mattresses would fall within the purview of Standard No. 302. I have enclosed a copy of the proposed rule for your further information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel