Interpretation ID: aiam0676
Director/General Manager
Toyota Motor Sales
U.S.A.
Inc.
Lyndhurst Office Park
1099 Wall Street
West
Lyndhurst
NJ
07071;
Dear Mr. Nakajima: This is in reply to your letter of March 30, 1972, in which you as whether, under the procedures of paragraph S5.2.1 of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' you may interpret the reference to materials having a 'thickness' exceeding 1/2 inch to mean the 'design thickness.' You request this interpretation because it appears that some materials having a design thickness of 1/2 inch or less may increase in thickness due to vibration or moisture absorbtion. In cutting these materials down to the 1/2-inch thickness for testing purposes, you say a fluffy surface is created which burns at a much higher rate than the material's original surface.; For purposes of testing for compliance with the standard, manufacturer are free to deviate from the procedures specified in the standard as long as the results they obtain can be correlated to results obtained using the test procedures of the standard. The test procedures specified in S5.2.1 are not, however, intended to result in a changing of the texture of a material's surface when the material is cut to the specified size. Consequently, while we cannot approve of the interpretation you request, we would consider a slight deviation in the thickness of tested materials from the 1/2-inch specification, in order to preserve the original surface of the material, to be consistent with the standard's test procedure. I point out further that the NHTSA is aware of the problems you have encountered, and is presently considering amendments to the standard which would alter this result.; Yours truly, Richard B. Dyson, Assistant Chief Counsel