Interpretation ID: aiam0602
Manager
Technical Administration Section
Mitsubishi Motors Corporation
33-8
5-Chome
Shiba
Minato-Ku
P. O. Box 17
Takanawa
Tokyo
Japan;
Dear Mr. Ishii: This is in reply to your letter of January 14, 1972, in which you as whether the vibrating paper cone of a cone-type radio speaker is required to meet the performance requirements of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You also ask whether the answer to this question depends upon whether the radio, although factory installed, is optional or standard equipment.; The relevant language of the standard as it is presently worded, i whether the cone is 'an interior material . . . designed to absorb energy on contact by occupants in the event of a crash' (S4.1). Whether or not the cone is within this language depends upon whether in fact it has been designed by the manufacturer for the stated purpose. It is of no consequence, further, whether the radio is standard or optional, if it is installed at the factory or before sale to the consumer. I would add that NHTSA presently has the above quoted language of S4.1 under review, and may modify it in future rulemaking which we expect to issue shortly.; In a conversation of February 4, 1972, it was indicated to Michae Peskoe of my staff that you had additional questions regarding the standard which you would submit to us in writing. You mentioned particularly whether a steering wheel would be subject to the standard. The answer, as in the case of the cone, is whether the manufacturer has designed it to be an energy-absorbing component.; We regret the delay in answering your letter, however, it was ou understanding that you would submit the aforementioned additional questions to us, and we would respond at that time to your letter of January 14. We have not received this additional correspondence from you.; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel