Interpretation ID: aiam0871
RVI Washington Counsel
Recreational Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC
20006;
Dear Mr. Humphreys: This is in reply to your letter of August 18, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to motor homes.; You ask whether the standard would be applicable to wood flooring tha lies immediately under carpeting which is attached to the wood flooring by staples and which forms an interior floor covering over either the wheel housing or over the flooring in general. Paragraph S4.1 lists 'floor coverings' among the components required to meet the requirements of the standard. Since carpeting is a floor covering, it would have to meet the requirements of the standard. The flooring underneath the carpeting would not be considered a 'floor covering' and, accordingly, would not have to meet the requirements. Because the flooring is not listed as a component to which the standard applies, the issue of whether the carpeting-flooring-staples combination is a composite material under Paragraph S4.2(b) of the standard does not arise.; In general, any method of joining materials may be a 'mechanica attachment' subject to the standard if it achieves an intimate joining of separate materials in any given component. The question is not so much how the attachment is made, but how closely spaced are the attachment points.; You ask further whether the standard would apply to wheel housin covers where the wheel housing or a portion thereof would not be exposed to the interior of the vehicle. Although wheel housing covers are included in Paragraph S4.1, any component subject to the standard must also be included within the general language of that Paragraph, which only refers to materials used in 'vehicle occupant compartments.' If the wheel housing cover or any portion of it is or may be exposed to the occupant compartment, such as by the folding of seats, beds, or other movable components, then it is subject to the requirements of the standard. If it is fully separated from the occupant compartment by a nonremovable barrier when any interior component is used (including folding or convertible seats or beds), then it is considered to be outside the occupant compartment and not subject to the requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel