Interpretation ID: aiam0727
Project Engineer
Blue Bird Body Company
Fort Valley
GA
31030;
Dear Mr. Milby: This is in reply to your letter of May 9, 1972, inquiring whethe temporary covering which is used to prevent soiling of upholstery during production, transportation, and sales demonstration must meet the requirements of Standard No. 302.; Whether the material must comply with the standard dependsupon (sic whether it is likely to be used in a significant number of cases by the purchaser as part of the motor vehicle. You have stated that the purpose of the material is to 'prevent soiling during production, transportation, and sales demonstrations.' It is important that this intent be carried out in practice, if the material is not to be considered vehicle interior material subject to the standard. Two criteria which would be considered in determining whether the material is covered by the standard are (1) whether it is placed in the vehicle in a way that its use after purchase is unlikely, and (2) what steps the manufacturer has taken to see that it is removed before sale to the purchaser. If Blue Bird does take steps to ensure that the material will not be used as a seat cover by the purchaser, then the material would not be required to conform to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel