Interpretation ID: 1985-02.29

TYPE: INTERPRETATION-NHTSA

DATE: 05/15/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

May 15, 1985 Mr. T. Chikada 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 seeding an interpretation of the requirements of Standard No. 302, Flammability of Interior Materials (49 CFR 571.302). 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 new vehicles which 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 new 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 the 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 questions in this area. Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel