Interpretation ID: aiam3500
Assistant Vice President
Textile Services Division
United States Testing Company
Inc.
14415 Park Avenue
Hoboken
NJ 07030;
Dear Mr. Dufresne: This responds to your July 24, 1981, letter directed to our Office o Enforcement in which you ask whether it would be permissible to test for compliance with Standard No. 302, *Flammability of Interior Materials*, in a manner different than that prescribed in the standard. The standard states that a 14-inch long section of material shall be burned in a test oven until the flame reaches within 1 1/2 inches from the end of the material. You state that for some fabrics this requires a test that can extend to 10 minutes. In a test of this length, the test oven can cause the glass front of the oven to break. You suggest that the test be discontinued after five minutes, and the burn rate calculated.; The test requirements of the standard are provided to show how th agency will test for compliance. However, it is not compulsory that a manufacturer adhere to every facet of the test procedures if it can satisfy itself that its product will comply with the standard by testing in another manner. As you know, the standard requires only that the burn rate of a material not exceed four inches per minutes. A 14-inch long section of material that has not burned completely to its end in five minutes obviously would not exceed the 4-inch per minutes burn rate. Accordingly, we do not see any reason that you could not terminate the test five minutes after the starting point specified in paragraph S5.3(e) of the standard.; Sincerely, Frank Berndt, Chief Counsel