Interpretation ID: aiam0529
Vice President
Allen Industries
Inc.
Honeywell Building
17515 West Nine Mile Road
Southfield
MI
48075;
Dear Mr. Nagle: This is in reply to your letter of October 28, 1971, requesting a interpretation of paragraph S4.3 of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether cotton seat padding or jute used on the backing of automobile carpets, when prepared as a test specimen of 1/2-inch thickness as prescribed by the standard, will comply with paragraph S4.3 if it transmits a flamefront across its surface at a rate of more than 4 inches per minute but stops burning in 10 to 20 seconds, and the material does not burn more than 2 inches from the point where timing was started.; On December 18, 1971, you indicated in a phone conversation wit Michael Peskoe of the Office of the Chief Counsel that your letter did not take into account a 'flashing' of the flame across a particular surface of the cotton seat padding for more than 2 inches. You stated that this surface is a tufted surface that is created only when the seat padding, which has a thickness of 4 inches in the vehicle, is cut or separated to the half-inch thickness specified in the procedure of S5.2.1 of the standard.; We consider the 'flashing' of the flame across the tufted surface o the material to be a burning of the material under S4.3 of the standard, and as it did occur for more than 2 inches from the point where timing was started, the material would not comply with paragraph S4.3.; We recognize, however, that the failure of the material to meet th requirements in this case results from the fact that the surface of the material changes because of the test procedure, and we are presently considering possible changes in the standard to alter this result.; Sincerely, Richard B. Dyson, Assistant Chief Counsel