Interpretation ID: aiam0680
Project Engineer
Blue Bird Body Company
Fort Valley
GA
31030;
Dear Mr. Milby: This is in reply to your letter of April 3, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to particular motor vehicle components, particularly components of motor homes. The components about which you inquire are listed below and are followed in each case by our response:; >>>1. Radio/Stereo speaker grills: When these components ar incorporated into components that are listed in S4.1, such as compartment shelves and trim panels, they must meet the requirements of S4.3. If they are not incorporated into such components they need not meet the requirements.; 2. Lens-dome light: Under the present wording of the standard, thes components are not covered unless they are designed to absorb energy on contact by occupants in the event of a crash.; 3. Decals: Decals are not listed in S4.1 and are not subject to th standard. However, when decals are part of a listed component they must be tested as part of that component.; 4. Pillows - Loose decorator type used in motor home: Pillows that ar not seat cushions are not included in S4.1 and are not subject to the requirements of the standard.; 5. Towels - Used in bathroom of motor home: These items, similarly t decorator-type pillows, are not listed in S4.1 and are not subject to the standard.; 6. Shower Curtain - Used in bathroom of motor home: The NHTSA consider the bathroom of a motor home to be an occupant compartment under S4.1 of the standard, and a shower curtain to be a curtain under that section. Consequently, a shower curtain is subject to the requirements of the standard.; 7. Bath Mat - Used in bathroom of motor home: A bath mat would be floor covering under S4.1 and would be subject to the standard.; 8. Drapery hardware is not subject to the standard. 9. Toilet and Toilet Seat: We would consider toilets and toilet seat to fall within the meaning of seat backs and seat cushions in S4.1, and consequently subject to the standard.; 10. Towel Ring - Used in bathroom: Towel rings are not listed in S4. of the standard and are not subject to its requirements.; 11. ABS plastic plumbing - Used in bathroom: Plumbing is not listed i S4.1 of the standard and is not subject to its requirements.; 12. Face plate covers - for receptacles and switches: If these plate are incorporated into or are part of components enumerated in S4.1, such as trim panels, they are subject to the requirements of the standard.; 13. Bathroom interior of motor home: As indicated above, the bathroo of a motor home is considered to be an occupant compartment.<<<; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel