Interpretation ID: aiam0761
P.E.
President
Resources Applications
Designs & Controls
Inc.
7045 Marcelle Street
Paramount
CA
90723;
Dear Mr. Waldman: This is in reply to your letter of June 13, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to recreational vehicles. You ask, under paragraph S4.1 of the standard, whether materials not designed to absorb energy on contact by occupants must conform to the standard, and list materials and components which you believe might be within this classification.; Except in the case of the components specifically enumerated in S4.1 components that are designed not to absorb energy on contact by occupants are not subject to the standard. Enumerated components must conform to the standard regardless of whether they are energy-absorbing.; With respect to the materials which you list, whether or not they mus meet the standard depends upon whether they are used in the manufacture of any of the components listed in S4.1, either as surface materials, underlying materials, or padding and cushioning materials. In some cases, consequently, insulating materials such as those you list could fall within the materials that should be tested. In each case the manufacturer must determine whether the material is part of the listed component.; With reference to the components you list, open cabinets and cabine tops would be considered under S4.1 to be compartment shelves and toilets would be considered to be seat backs and seat cushions. Walls would be classified as trim panels. Lavoratories and shower doors are not within the enumerated components.; You also ask, in the case of unitized walls having a depth of 2 inche or more, whether the test should be limited to a section 1/2 inch thick. The thickness of the tested sample depends upon the portion of the component which is tested pursuant to paragraphs S4.2(a), S4.2(b), and S4.2(c). In each case, the portion of the material that is tested is cut to a 1/2 inch thickness when the portion of the material as it appears in the vehicle exceeds that thickness (S5.2.1).; Yours truly, Richard B. Dyson, Assistant Chief Counsel