Interpretation ID: 24169

Mr. Delmer T. Brower
Ortech Designer
2806 North Industrial Road
Kirksville, MO 63501

Dear Mr. Brower:

This responds to your e-mail of March 12, 2002, in which you request information on Federal Motor Vehicle Safety Standard (FMVSS) No. 302, "Flammability of Interior Materials." Each of your questions is answered below.

In your e-mail, you state that Ortech manufactures plastic ignition cylinder bezels and glove box lock cylinders for a Lockset supplier to a motor vehicle manufacturer. These bezels and cylinders are installed within 13 mm of the occupant compartment air space. You ask whether these items "are considered an integral part of the front trim panel listed in S4.1" of Standard No. 302, thus requiring the testing specified in S4.3. If this testing is required, you ask whether Ortech, as the original equipment manufacturer, is required to perform it.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Standard No. 302 specifies burn resistance requirements for materials used in the occupant compartments of motor vehicles. Section S4.1 lists the components in vehicle occupant compartments that the vehicle manufacturer must certify as complying with the flammability resistance requirements of paragraph S4.3. The components listed include seat cushions, seat backs, seat belts, headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, and 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. S4.2 requires any portion of the components listed in S4.1 that is within 13 mm of the occupant compartment air space to meet the requirements of S4.3.

The Ortech ignition cylinder bezels and glove box lock cylinders are installed in a vehicle's front trim panel. Front trim panels are listed as a component that must be certified as complying with S4.3. Under S4.2, if any portion of a front trim panel is within 13 mm of the occupant compartment air space, that portion must comply with S4.3. Accordingly, since the Ortech ignition cylinder bezels and glove box lock cylinders are located within 13 mm of the occupant compartment air space, they must comply with S4.3.

You also asked who is responsible for performing certifying that these items comply with S4.3. Since Standard No. 302 is a vehicle standard, the manufacturer of the vehicle, and not the manufacturer of the individual component, is responsible for certifying compliance with Standard No. 302.

I hope you find this information helpful. If you have any further questions, please feel free to contact Dion Casey of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

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