Interpretation ID: aiam0591
Manager
Foam Sales & Engineering
Keyston Brothers
1000 Brannan Street
San Francisco
CA
94103;
Dear Mr. Warner: This is in reply to your letter of February 9, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to an interior upholstered panel that you manufacture. You state that the panel is made up of a vinyl surface, a self-extinguishing foam, and a backing, and that the three materials must be tested as a single unit, or separately.; Paragraph S4.2 of Standard No. 302 specifies as follows:>>>S4.2 Th portions of the components that shall meet the requirements of S4.3 are all of the following:; (a) The surface material taken separately if it is not bonded, sewed o mechanically attached to underlying material.; (b) A composite consisting of the surface material bonded, sewed o mechanically attached to underlying material, if such a composite is used in the component.; (c) Padding and cushioning materials taken separately, if thos materials are not bonded, sewed or mechanically attached to surface materials.<<<; Under the language of S4.2, your surface material, and the underlyin foam should be tested as a composite pursuant to subparagraph (b). If the backing is considered a padding or cushioning material, it should be tested separately pursuant to subparagraph (c).; A notice of proposed rulemaking which would amend paragraph S4.2 wa published May 26, 1971 (36 F.R. 9565), and a copy is enclosed for your information. We expect that a final rule based on this proposal will be published in the near future. Under the wording of the proposal your material would be tested under subparagraph (b) to a depth of 1/2 inch, and padding and cushioning material would be tested again under subparagraph (c).; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel