Interpretation ID: aiam0788
Quality Control Manager
Crown Steel Products Division
1330 North Main Street
Orrville
OH
44667;
Dear Mr. Sniff: This is in reply to your letter of June 30, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' asking for a determination of the term 'passenger compartment' in a van-type vehicle that has either a partial partition behind the driver's seat or no partition at all.; We would consider a reasonable interpretation of the phrase 'occupan compartment' found in S1 of the Standard, when applied to van-type trucks which have no physical barrier between the occupant and cargo compartments, to be that area forward of a vertical plane perpendicular to the longitudinal centerline of the vehicle and tangent to the rearmost point of any occupant seat in its rearmost position. In the case where there is a partial partition behind the driver's seat, we would consider the 'occupant compartment' to be that area forward of a vertical plane that constitutes an extension of the partial partition and is perpendicular to the longitudinal centerline of the vehicle. The cargo areas of such vehicles would not be considered 'vehicle occupant compartments' under S4.1 of the Standard, and the materials used in the cargo area need not comply with the Standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel