Interpretation ID: aiam3940
Manager
Automotive Lighting
Engineering Control Department
Stanley Electric Co.
Ltd.
2-9-13
Nakameguro
Meguro-ku
Tokyo 153
Japan;
Dear Mr. Chikada: This responds to your recent letter to this office seeking a interpretation of the requirements of Standard No. 302, *Flammability of Interior Materials* (49 CFR S571.302). Specifically, you asked whether center high-mounted stop lamps are required to comply with the flammability requirements of Standard No. 302. They are not required to do so.; Section S4.1 of Standard No. 302 lists all the components in ne vehicles which are required to comply with the flammability requirements of the standard. The only item on the list in section S4.1 which might conceivably apply to center high-mounted stop lamps is 'any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.' Assuming that your center high-mounted stop lamps are not designed to absorb energy on contact by an occupant, they would not be required to comply with the requirements of Standard No. 302.; Although interior lights are not required to comply with th requirements of Standard No. 302, the agency has noted that almost all such lights now in production use fire-resistant plastic lenses and fixtures. Liability might be found under State and common law if the newly required center high-mounted stop lamps were to incorporate highly flammable plastic components, while the other interior lights incorporated fire-resistant plastic components.; Please do not hesitate to contact me if you have any further question in this area.; Sincerely, Jeffrey R. Miller, Chief Counsel