Interpretation ID: aiam0403
Automotive Safety Director
Ford Motor Company
The American Road
Dearborn
MI
48121;
Dear Mr. Eckhold: This is in reply to your letter of March 26, 1971, raising question concerning Federal Motor Vehicle Safety Standard No. 302 that were initially asked by Ford at a meeting held with Administration representatives on March 9, 1971. Since the time of your letter, as you know, the Administration has proposed an amendment to the standard to clarify the requirements for separate and composite materials and one aspect of the test procedure. As the Administration intends that this proposal become effective on the standard's present effective date of September 1, 1972, our answers to your questions are based, where appropriate, on the proposed amendment as well as the present text of the standard.; We have restated your questions below, and have modified the answer you have provided where appropriate.; >>>1. What interior parts are covered by this standard . . .<<< A list of components which we believe to be included is attached. Your statement that ' . . . parts specifically named in the standar (are) included, as well as padded or crash-deployed elements designed to absorb energy in a crash' is incomplete, as it limits energy-absorbing elements to only padding or crash-deployed elements. S4.1 of the standard refers to padding and crash-deployed elements only as examples of energy-absorbing elements.; With reference to the list of components you have provided, it i difficult to determine without the exact configuration of each component whether it is subject to the standard's requirements. However, based upon the literal wording of S4.1, of those items you have listed, the following are specifically subject to the standard: arm rests (seat mounted) including pad and base, arm rests (door or trim panel mounted) including pad and base, package tray trim panels, truck rear compartment shelves, convertible backlight curtains, truck rear compartment curtains, floor carpeting including backing and sound deadener, floor mats, seat cushion and (seat) back pads, seat cushion and (seat) back covers, including threads and welts, window shades, convertible tops, engine compartment covers, headlining, head restraints, truck mattress covers, seat belts and shoulder harness, webbing and seat belt covers, sun visors, trim panels, including door, front, rear, side, station wagon cargo, and cowl side trim panels.; The following items that you have listed are not specificall enumerated in S4.1 of the standard, but apparently closely resemble or are merely different descriptions of items that are enumerated. If so they are subject to the standard: Exposed instrument panel package shelves, pillar covers, roof console, scuff plates, ash tray covers, storage boot for convertible tops, glove compartment box if not covered by door, and glove box doors (instrument panel or console).; The following components that you have listed, depending on thei actual configurations, would quite possible be covered under the language 'any other materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.' Some components previously listed are repeated here, as they may fall within more than one category: instrument panel crash pads, crash- deployed elements (air bags and air bag-deployment doors), steering wheel pad assembly, hub emblem, cover assembly, emblem assembly, horn-blowing assembly, button assembly, and buttom (sic) assembly medallion, glove compartment doors, and ash try covers.; The following item would also be included as it is incorporated into surface or component that is subject to the requirements of S4.1: radio speaker grilles on doors or package tray trim panels.; We do not know the nature of the following components, and offer n opinion concerning whether they must meet the requirements: dash insulators, truck floor heat deflectors, door and quarter watershields, if exposed, and truck heater cover when mounted on engine cover.; The information provided above is based solely on the list provided and does not apply to any interior component that is not listed. Furthermore, we offer no opinion as to whether this list is exhaustive with regard to interior components, and point out that other components that are not listed may have to comply with the standard's requirements.; >>>2. Should seat welts be tested as loose pieces or attached t covers?<<<; Seat welts are considered part of the seat cover and should be teste as part of the seat cover.; >>>3. How is a part which is less than the specified size for a sampl to be tested?<<<; A part smaller than the specified sample size should be tested usin the thin, heat-resistant wires described in S5.1.3.; >>>4. A foamed-in-place trim panel could have several burn rate result because of varying shapes and thickness. How should samples be taken for testing?<<<; The sample should be chosen so that it will produce the most advers result when tested to the standard's requirements.; >>>6. Some package tray trim panels may include speaker holes or grill cloth in localized areas. How should the sample be taken for testing?<<<; The speaker grille cloth should be tested separately from the tri panel material.; >>>7. A given seat cover may employ several different kinds o material. Should all variations be tested?<<<; Yes. The requirements of the standard must be met by each variation i the materials.; >>>8. Are sewing threads considered surface materials?<<< Any material that contains threads that are used in sewing it t another should be tested with the threads as they appear in the material.; >>>9. Does bonded mean all methods of adhering materials?<<< The use of the term 'bonded' is intended in the sense that th materials adhere to each other at every point of contact. The proposed amendment eliminates the use of this term.; >>>10. Does underlying material refer only to the layer immediatel beneath the surface cover?<<<; No. It applies to all materials beneath the surface material. There i no depth limitation. The half-inch specification refers only to maximum sample thickness of S5.2.1.; >>>11. Paragraph S4.2(b) describes a composite. If a component is onl partially bonded should the composite be tested or individual parts.<<<; For purposes of the standard you have described two components, on that is bonded, and one that is not. Both must meet the standard's requirements.; >>>12. When padding materials are not bonded to surface materials, bu are bonded to substrate boards, are they considered as composite or separate pieces. The sun visor . . . was discussed as an example.<<<; Under both the present and the proposed wording of S4.2, an underlyin material that is not bonded to surface material would be treated as a separate material even if it is bonded or similarly attached to another underlying material. However, surface materials include more than the exposed surface of the vehicle interior. They include as well any undersurface, such as in certain vehicle seats or package shelves. In some cases, therefore, a substrate board may be a surface (undersurface) material, and thus be required to meet the requirements for surface materials. With reference to the sun visor, a sample of which was left with us, it should be treated as a component having two surfaces. The interior materials should be treated as underlying padding or cushioning material.; >>>13. Paragraph S5.1.3 calls for the use of support wires if errati burning results. At what point should this be done?<<<; The statement, 'NHTSA believes that support wires will not influenc the results' is correct, and the manufacturer may use the support wires whenever he wishes. Erratic burning includes, but is not necessarily limited to, burning at a non- uniform rate.; >>>14. Paragraph S5.2.1 -- Should samples from contoured, foame assemblies be cut so that a uniform 1/2 inch thickness results?<<<; We believe that samples of uniform thickness are preferable to thos that are not. The standard requires only that the specimen not exceed 1/2-inch thickness at any point.; >>>15. Paragraph S5.2.2 -- Is warp and fill testing for yard good adequate or should bias testing be conducted?<<<; The sample should be tested so as to produce the most adverse results. >>>16. Paragraph S5.3(d) -- Should flame be removed or shut off afte beginning of the test?<<<; While not specified in the standard, we are of the opinion tha shutting off the flame is preferable to withdrawal of the burner as the former will produce less change in the ambient conditions inside the test cabinet.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel