Interpretation ID: aiam0604
Director/General Manager
Toyota Motor Sales
U.S.A.
Inc.
Factory Representative Office
Lyndhurst Office Park
1099 Wall Street West
Lyndhurst
NJ
07071;
Dear Mr. Nakajima: This is in reply to your letter of February 3, 1972, regarding th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to certain vehicle components which you enumerate.; You state that you do not consider the 'steering column tube cover' an the 'steering column cover' to be of 'any other materials . . . designed to absorb energy on contact by occupants in the event of a crash' in S4.1, and that it is your understanding that they are therefore excluded from the application of the standard. If these components are not in fact designed to be energy absorbing then your conclusion is correct.; You also ask whether the center console or air conditioner grilles ar required to comply with the standard. The answer again depends upon whether they are within the above quoted language of S4.1. I point out that the NHTSA is presently reviewing this particular requirement, and it may be modified in rulemaking which we expect to publish in the near future.; Finally, you ask for the specific meaning of the term 'trim panels' a used in S4.1. The phrase 'all trim panels, including door, front, rear, and side panels,' is intended to refer to various rigid or semirigid interior coverings, such as door, scuff, and other covering panels, which appear on the front, sides, and rear of the occupant compartment of motor vehicles.; Yours truly, Richard B. Dyson, Assistant Chief Counsel