Interpretation ID: aiam0875
General Manager
Daicel Ltd.
New York Liaison Office
200 Park Avenue
New York
NY
10017;
Dear Mr. Morita: This is in reply to your letter of September 15, 1972, to Mr. Jerome A Palisi, requesting information concerning the application of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to various components of vehicle occupant compartments made of plastic or plastic and metal.; The components that must meet the requirements of the standard ar listed in paragraph S4.1. Some of the components you have asked about are covered by the standard and others are not. Dashboards and instrument panels are considered to be 'front panels' and are therefore covered. Steering wheels normally are 'designed to absorb energy ... in the event of a crash' and, in that case, are covered. The components not covered specifically are handles of handbrakes, meter housings, steering column covers, console boxes, and handle knobs to open and shut windows. These components, such as console boxes, will nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash.' We cannot identify what you mean by 'change lever knobs' and, therefore, we cannot comment on this component.; You also ask whether finished or unfinished components should be teste according to the procedures described in S5 of the standard, and what kind of specimens should be prepared for plastic components with metal insertions. The standard does not apply to intermediate or unfinished materials, and compliance testing by the Government is carried out with components removed from motor vehicles that have been marketed. Test specimens should be prepared according to S5.2.1 of the standard regardless of the materials that are present in a given component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel