Interpretation ID: aiam0370
Engineering Representative
Nissan Motor Co.
Ltd.
Liaison Office in U.S.A.
400 County Avenue
Secaucus
NJ
07094;
Dear Mr. Mizuno: This is in reply to your letter of May 10, 1971, concerning coverin material for seats and door trim that is used solely to protect the interior of the vehicle during transportation from the manufacturer to the dealer. You have asked whether this covering material is required to comply with the flammability requirements of Standard No. 302.; Whether the material must comply with the standard depends upon whethe it is likely to be used in a significant number of cases by the purchaser as part of the motor vehicle. You have stated that the only purpose of the material is 'to insure the delivery of a car in which the interior is in good condition.' It is important that this intent be carried out in practice, if the material is not to be considered vehicle interior material subject to the standard. Two criteria which would be considered in determining whether the material is covered by the standard are (1) whether it is placed in the vehicle in a way that its use after purchase is unlikely, and (2) what steps the manufacturer has taken to see that it is removed before sale to the purchaser.; We cannot make a final determination as to whether such material mus meet the requirements without more information, particularly with respect to the questions noted above. However, if Nissan does take appropriate steps to ensure that such material will not be used as a seat cover by the purchaser, then the material would not be required to meet the requirements of the Standard.; We are pleased to be of assistance. Sincerely,Lawrence R. Schneider, Acting Chief Counsel