Interpretation ID: aiam0770
Vehicle Safety Manager
Lotus Cars Ltd.
Norwich NOR 92W
Wymondham 3411
England;
Dear Mr. Doe: This is in reply to your letter of June 12, 1972, asking certai questions concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask if the standard applies to small components that have a maximu dimension of less than 4 inches, such as control knobs, and if so, how such components are to be tested. The standard applies to those components enumerated in S4.1. Control knobs and switches would not be subject to the standard unless they are 'designed to absorb energy on contact by occupants in the event of a crash.' Such components may be tested using the heat resistant wires that are inserted in the U-shaped frame, as described in paragraph S5.1.3 of the standard. The NHTSA is currently considering an amendment to the standard, however, which would modify the requirements as they apply to small components.; In response to your second question, electrical wiring is not subjec to the standard.; Your third question is, if a headliner is glued to the roof, would th test specimen be taken from a finished vehicle in such a way as to include the exterior paintwork. The answer to this question is no. The application of the standard to headlining (S4.1) does not include the roof to which it is attached, as the roof is not part of the component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel