Interpretation ID: aiam0603
Liaison Engineer
Chief
Toyo Kogyo Co.
Ltd.
3841 Mystic Valley Drive
Bloomfield Hills
MI
48013;
Dear Mr. Utsunomiya: This is in reply to your letter of January 28, 1972, in which you lis specific interior components and ask whether they are required to comply with Standard No. 302, 'Flammability of Interior Materials.' You state that these components are not designed to be energy absorbing in some vehicles.; With regard to the parcel shelf and scarf plate, as we indicated to yo in our letter of September 24, 1971, these components appear to closely resemble or to be merely different descriptions of items that are enumerated in S4.1 of Standard No. 302. If so, they must comply with the requirements. We also mentioned to you in that latter than seaming welt and seaming rubber should be considered as part of the component to which it is attached, and for which it provides a seam.; With regard to the other items you list, you should consider th language of S4.1 that reads, '. . . other interior materials . . . designed to absorb energy on contact by occupants in the event of a crash.' If in fact, as you indicate, these components are not so designed, then they need not meet the requirements of the standard. I would add that NHTSA is presently reviewing this requirement, and it may be modified in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel